Corrective Action Plans

Finding 1182825 (2025-006)

Material Weakness 2025

State of Vermont

VT

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A5...

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A55UI000063 (10/1/2023 – 12/31/2026) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 23A60UB000024 (4/1/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) UI347462055A50 (8/20/2024 – 8/20/2027) 23A60UD000013 (7/14/2023 – 7/14/2026) 25A60UD000067 (10/1/2024 – 9/30/2027) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that policies and procedures be implemented to ensure that all reports are reviewed by an authorized State official prior to submission and that supporting documentation providing evidence of supervisory review is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: These reports are filed by our Labor Market Information division on behalf of the UI Division. The LMI employee responsible for these reports takes the data from a server/system generated report and enters it into a federal reporting system. Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that reports are reviewed and approved by authorized State officials prior to submission. From now on the employee responsible for these reports will have their immediate supervisor review both reports to certify and signoff that the submitted report matches the system generated report and that they were submitted timely. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristin.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182824 (2025-005)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Nu...

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Award Number and Year: B-20-RH-50-0001 (1/17/2022 - 2/1/2029) B-22-RH-50-0001 (3/27/2023 - 9/1/2029) B-23-RH-50-0001 (7/1/2023 - 9/1/2030) B-22-DC-50-0001 (7/1/2022 - 9/1/2029) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: We have developed specific fields in the online grants management system, GEARS to manage the process of input into SAM.GOV of grant agreements and amendments by the execution date. In addition, the SAM.GOV system clearly identifies the “Subaward Date” stating “enter the date you have signed the subaward.” Staff have been trained appropriately on both GEARS and SAM.GOV to ensure the correct Subaward Date is entered. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Ann Karlene Kroll, DHCD Federal Programs Director, annkarlene.kroll@vermont.gov

View Audit 394235

Finding 1182823 (2025-004)

Material Weakness 2025

State of Vermont

VT

Eligibility Reporting Special Tests & Provisions § 200.303

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2...

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2026) 4VT437533 (10/1/2023 – 9/30/2025) Compliance Requirement: Special Tests and Provisions – ADP System for SNAP Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that eligibility case reviews are performed timely, accurately, and are properly documented. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: A majority of the findings from the 2025 audit predate the completion of corrective actions associated with Audit 2024-004. Because the corrective action completion date was April 18, 2025, these issues resulted in repeat findings related to supervisory case reviews. To address this, the 3SquaresVT Food and Nutrition Team will review the findings with ESD Operations and present examples, along with refresher training on the Supervisor Case Review (SCR) process, at the District Directors Meeting on February 11, 2026. In addition, a new column will be added to the SCR tracking spreadsheet to allow supervisors to document the date corrective actions were completed when revisions are required following a review. The refresher training and the updated SCR tracking spreadsheet are expected to prevent the recurrence of these findings during the 2026 Single Audit. Scheduled Completion Date of Corrective Action Plan: February 11, 2026 Contacts for Corrective Action Plan: Jessica Duranleau, ESD Program Manager, jessica.duranleau@vermont.gov Leslie Wisdom, Food and Nutrition Program Director, leslie.wisdom@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

View Audit 394235

Finding 1182821 (2025-003)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1...

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior year. It should review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to SAM.gov in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The business office will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “FFATA reportable” upon grant execution in the Agency’s grants and contracts workbook. The Financial Directors will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the appropriate Federal system by the last business day of each month. Scheduled Completion Date of Corrective Action Plan: 4/30/26 Contacts for Corrective Action Plan: Amy Mercier, Financial Director, amy.mercier@vermont.gov Karen Mae Smith, Financial Director, karenmae.smith@vermont.gov

View Audit 394235

Finding 1182820 (2025-002)

Material Weakness 2025

Lehigh University

PA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the...

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

View Audit 394233

Finding 1182817 (2025-007)

Material Weakness 2025

Circle of Nations School INC

ND

Allowable Costs / Cost Principles § 200.430

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identifie...

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identified an expenditure where payroll benefits were not paid in accordance with the employment letter. Responsible Individuals: Trevor Gourneau, Superintendent Corrective Action Plan: The School will review internal controls surrounding allowable costs and activities to exsure they are adequate to identify unallowable expenditures. Anticipated Completion Date: June 30, 2026

View Audit 394228

Finding 1182816 (2025-002)

Material Weakness 2025

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. E...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: April 2026

View Audit 394224

Finding 1182814 (2025-001)

Material Weakness 2025

Southwestern Oregon Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Expla...

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue to review policies and procedures for accurate reporting. Investigate and identify discrepancies being exported by the Student Information System (Jenzabar). Have additional staff member review file and sign off before the data is submitted. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: June 2026

View Audit 394224

Finding 1182810 (2025-002)

Material Weakness 2025

Taylor Brown Hdf CO (east Main Street Apartments

NY

HUD Housing Programs

Finding 2025-002: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: We recommend that East Main Street Apartments resume unit inspections and ensure those inspections are properly documented in the tenant files. Views of management and planne...

Finding 2025-002: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: We recommend that East Main Street Apartments resume unit inspections and ensure those inspections are properly documented in the tenant files. Views of management and planned corrective action: East Main Street Apartments has resumed unit inspections and will ensure those inspections are properly documented in the tenant files. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394208

Finding 1182809 (2025-001)

Material Weakness 2025

Taylor Brown Hdf CO (east Main Street Apartments

NY

HUD Housing Programs

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUD...

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: East Main Street Apartments should ensure residual receipts are made within 90 days of year-end in accordance with the HUD Regulatory Agreement. Views of management and planned corrective action: East Main Street Apartments agrees with the finding and will make the required payment. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394208

Finding 1182808 (2025-001)

Material Weakness 2025

Geneva General Housing Development Fund Company, Inc.

NY

HUD Housing Programs

Audit period: January 1, 2025 – December 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Fi...

Audit period: January 1, 2025 – December 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance - Rental Housing (Section 207), Federal Assistance Listing Number 14.134 Recommendation: Our auditors recommended that we resume unit inspections and ensure those inspections are properly documented in the tenant files. Action Taken: We are currently in the process of completing and documenting unit inspections. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821. Anticipated Completion Date: April 2026

View Audit 394206

Finding 1182807 (2025-001)

Material Weakness 2025

St. Anthony School and Daycare/preschool of St. Anthony Congregation

WI

Procurement, Suspension & Debarment § 200.320

Corrective Action Plan: Beginning with the 2026-2027 school year, the organization will follow our Federal Funds Procurement Policy and obtain a minimum of 3 bids for vendors whose purchases exceed $100,000 a year. Anticipated Corrective Action Plan Completion Date: June 30, 2027

View Audit 394205

Finding 1182803 (2025-003)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

HUD Housing Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance,...

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Rogers Senior has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Finding 1182802 (2025-002)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

HUD Housing Programs

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Rogers Senior Apartments should ensure residual receipts are made within 90 days of year-end in accordance with the HUD Regulatory A...

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Rogers Senior Apartments should ensure residual receipts are made within 90 days of year-end in accordance with the HUD Regulatory Agreement. Views of management and planned corrective action: Rogers Senior Apartments agrees with the finding and will make the required payment. Anticipated Completion Date: March 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Finding 1182801 (2025-001)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

Internal Control / Segregation of Duties

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Finding 2025-001: Board Meetings Recommen...

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Finding 2025-001: Board Meetings Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Rogers Senior Apartments has drafted an annual report of directors and are scheduling an annual meeting. Additionally, Rogers Senior Apartments has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Finding 1182799 (2025-002)

Material Weakness 2025

Loretto Apts at O'Brien Road Hdfc, Inc. (o'brien Rd SR Appts 2)

NY

HUD Housing Programs

Finding 2025-002: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 (Continued) Recommendation: Our auditor’s recommended that we ensure sufficient operating cash flow to make all required reserve for replacement deposits in the future. Views of management an...

Finding 2025-002: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 (Continued) Recommendation: Our auditor’s recommended that we ensure sufficient operating cash flow to make all required reserve for replacement deposits in the future. Views of management and planned corrective action: Management concurs. The December payment was made on January 9, 2026. Action Taken: The December payment was made on January 9, 2026. Completion Date: January 9, 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821

View Audit 394200

Finding 1182798 (2025-001)

Material Weakness 2025

Loretto Apts at O'Brien Road Hdfc, Inc. (o'brien Rd SR Appts 2)

NY

HUD Housing Programs

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. Findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Fi...

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. Findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 Recommendation: Our auditor’s recommended that O’Brien Road Senior Apartments 2 remit the overage of $14,632 to HUD’s Accounting Center or submit HUD 9250 for HUD approved application if directed. Views of management and planned corrective action: Management concurs and will submit form HUD 9250. Action Taken: Management is in the process of submitting form HUD 9250. Anticipated Completion Date: May 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821

View Audit 394200

Finding 1182795 (2025-002)

Material Weakness 2025

St. Peter's Italian Church Housing Development Fund Co., Inc.

NY

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Finding 2025-001: U.S. Department of Housing and Urban Development - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 See Findings – Financial Statement Audit Finding 2025-002: U.S. Department of Housing and Urban D...

Finding 2025-001: U.S. Department of Housing and Urban Development - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 See Findings – Financial Statement Audit Finding 2025-002: U.S. Department of Housing and Urban Development - Program: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Villa Scalabrini strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Villa Scalabrini has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821. Anticipated Completion Date: March 2026

View Audit 394197

Finding 1182794 (2025-001)

Material Weakness 2025

St. Peter's Italian Church Housing Development Fund Co., Inc.

NY

Internal Control / Segregation of Duties

Audit period: October 1, 1899 – September 30, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Finding 2025-001: Board Meetings Recomme...

Audit period: October 1, 1899 – September 30, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Finding 2025-001: Board Meetings Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Villa Scalabrini has drafted an annual report of directors and are scheduling an annual meeting. Additionally, Villa Scalabrini has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424-1821. Anticipated Completion Date: April 2026

View Audit 394197

Finding 1182793 (2025-001)

Material Weakness 2025

Greenfield Community College

MA

Student Financial Aid

Corrective Action Plan: On January 29, 2025, the Registrar updated the student’s withdrawal date in the Banner system (SFAWDRL). We expected the revision to be included in the subsequent monthly enrollment reporting file submitted to the National Student Clearinghouse (NSC). During our review, we de...

Corrective Action Plan: On January 29, 2025, the Registrar updated the student’s withdrawal date in the Banner system (SFAWDRL). We expected the revision to be included in the subsequent monthly enrollment reporting file submitted to the National Student Clearinghouse (NSC). During our review, we determined that this student was not included in the February 2025 NSC submission. To prevent this issue in the future, the Registrar’s Office will manually report revised withdrawal dates directly to NSC for any student identified by the Financial Aid Office as an unofficial withdrawal requiring a date adjustment. In addition, the college may collaborate with the IT department to review the parameters used to generate the monthly NSC enrollment reporting extract to ensure that students with revised withdrawal dates are consistently included in future submissions. Contact Person Mark Boudreau, Comptroller

View Audit 394181

Finding 1182791 (2025-001)

Material Weakness 2025

West Virginia State University Research and Development Corporation

WV

Cash Management

United States Department of Agriculture R&D Cluster – Assistance Listing No. 10.205 Condition: The Corporation elected to draw projected expenditures on a grant beyond what was an immediate and actual cash need. Recommendation: Management should review the process and procedures over cash management...

United States Department of Agriculture R&D Cluster – Assistance Listing No. 10.205 Condition: The Corporation elected to draw projected expenditures on a grant beyond what was an immediate and actual cash need. Recommendation: Management should review the process and procedures over cash management. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WVSU Research and Development Corporation will implement strengthened cash management procedures to ensure that federal funds are drawn only to meet immediate disbursements needs. Specifically, the organization will reinforce the monthly reconciliation process to compare drawdowns, actual cash expenditures and cash on hand in order for excess cash balances to be identified and corrected immediately. Name(s) of the contact person(s) responsible for corrective action: Kimberly Duff Planned completion date for corrective action plan: 02/01/2026

View Audit 394179

Finding 1182790 (2025-001)

Material Weakness 2025

City of Temecula

CA

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303 § 200.326

2025-001 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: S...

2025-001 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Management’s Response: We concur. Views of Responsible Officials and Corrective Action: During most of the fiscal year (July through April), the City monitored certified payroll reports (CPRs) monthly as part of its construction oversight procedures. Documentation of this monitoring was maintained through email communications and supporting records. In April 2025, following the FY24 Single Audit, the City evaluated its procedures and implemented enhanced controls to better align with federal requirements by requiring weekly monitoring and tracking of CPR submissions. These enhanced procedures were implemented to strengthen internal controls over compliance with federal prevailing wage requirements. Beginning in May 2025, CHA Consulting (formerly Falcon Engineering), the City’s outside consultant, began providing a weekly certified payroll tracking spreadsheet and the requested payroll documentation for selected contractors to the City’s Project Manager for review. The City documented the receipt, review, and follow-up actions through email correspondence and maintained supporting records of these activities. In addition, Public Works staff and the City’s consultants responsible for contract administration and labor compliance monitoring were provided updated guidance regarding federal prevailing wage requirements, including the requirement for weekly certified payroll submissions and documentation of review. Project Manager oversight was incorporated into the process to verify the accuracy of the certified payroll tracking log and ensure that reviews are performed consistently. This oversight provides an additional level of verification that monitoring procedures are conducted in accordance with federal requirements. Although the City enhanced its monitoring procedures, contractors and subcontractors did not always submit certified payroll reports within seven days as required under 29 CFR §3.4. The City continues to reinforce timely submission requirements with contractors and monitors compliance through the weekly tracking process. When certified payroll submissions are not received within the required timeframe, the City follows up with the contractor requesting immediate submission and documents the corrective actions taken. The City remains committed to strengthening its monitoring procedures to ensure timely submission, tracking, and documented review of certified payroll reports. In the event of payroll delinquencies, the City will take appropriate follow-up actions with contractors and may withhold progress payments when necessary to enforce compliance. In addition, the City is implementing new contract provisions in federally funded Public Works contracts to establish clear authority and enforce compliance with federal labor standards. These provisions include: • Requiring weekly certified payroll reporting in accordance with federal regulations • Authorizing the withholding of progress payments for non-compliance • Requiring contractors to communicate labor compliance requirements to all subcontractors • Requiring the use of electronic certified payroll reporting systems, where applicable • Allowing the City to conduct payroll audits and worker interviews as permitted under federal labor compliance regulations These contract provisions are intended to further strengthen the City’s internal controls and ensure compliance with federal prevailing wage requirements on federally funded projects. The City will continue to monitor the effectiveness of these procedures and will update its internal controls as necessary to ensure ongoing compliance with federal labor compliance requirements. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2026

View Audit 394175

Finding 1182789 (2025-001)

Material Weakness 2025

Hanac, Inc. and Affiliates

NY

Eligibility HUD Housing Programs Material Weakness

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2025. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The finding from the June 30, 2025...

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2025. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The finding from the June 30, 2025 consolidated and combined schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None reported. FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Material Weakness FINDING 2025-001 Eligibility U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan Condition: During our testing, we noted that the income verification of tenant eligibility through Enterprise Income Verification (“EIV”) system was not performed timely. Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: Management agrees with the recommendation and has begun to implement the following: • A checklist form will be completed for every certification and signed off once file is approved. • An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. • The file setup format and recertification updates will be monitored on a monthly basis. • EIVs are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. • Annual inspections are being scheduled as per Annual Recertifications are being processed. • Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. • Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module. Expected completion date: 07/31/2026 If any cognizant or oversight agency has questions regarding this plan, please call Lola Maroulis, Chief Financial Officer at 212-840-8005, extension 111. Sincerely yours, Lola Maroulis, Chief Financial Officer

View Audit 394172

Finding 1182788 (2025-001)

Material Weakness 2025

Town of Longmeadow

MA

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Pub...

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Public Schools will update internal control procedures to require that all invoices charged to federal grants explicitly state the dates of service. Staff pro-cessing invoices against Federal grant funds will be instructed to verify these dates against the au-thorized period of performance listed on the Grant Award Notification before processing payment. Staff Training: The Town will conduct mandatory training for the Special Education Department and central office administrative support staff. This training will focus on 2 CFR §200.309, specif-ically emphasizing that costs are only allowable if incurred during the approved budget period, re-gardless of when the invoice is received or paid. Name of Contact Person: Thomas Mazza, Assistant Superintendent for Finance and Operations, Longmeadow Public Schools, tmazza@longmeadow.k12.ma.us Completion Date: Prior to July 1, 2026

View Audit 394167

Finding 1182785 (2025-006)

Material Weakness 2025

Missouri Valley College

MO

Student Financial Aid

Finding Number: 2025-006 Title: Policies and Procedures Related to Reporting To rectify these discrepancies, the College will implement a reconciliation and review process for the FISAP. The Chief Financial Officer (CFO) will review the FISAP to ensure that all reporting accurately reflects the curr...

Finding Number: 2025-006 Title: Policies and Procedures Related to Reporting To rectify these discrepancies, the College will implement a reconciliation and review process for the FISAP. The Chief Financial Officer (CFO) will review the FISAP to ensure that all reporting accurately reflects the current fiscal year’s totals in relation to drawdowns and expenditures. Specifically, it has been noted that the FISAP had incorrectly listed totals from the previous year rather than the accurate amounts recorded in the General Ledger (GL) and Common Origination and Disbursement (COD) system. This oversight will be addressed through the establishment of a detailed CFO review. A standardized procedure to reconcile the FISAP data with the drawdowns recorded in the G5 system and the actual expenditures will be created. This procedure will involve a systematic review of all financial aid programs, ensuring consistency and accuracy before submission of the FISAP. By enacting this corrective action plan, the College aims to ensure that its reporting practices meet federal guidelines and maintain the integrity of its financial aid programs. Management is committed to these actions and will ensure their timely and effective execution. Anticipated Completion Date: March 31, 2026

View Audit 394160

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