Corrective Action Plans

Finding 1165383 (2025-003)

Material Weakness 2025

MN

Eligibility School Nutrition Programs

Contact Person – Randal Bergquist, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure students are receiving a reduced meal and the appropriate rate. Completion Date – January 31, 2026

View Audit 375994

Finding 1165378 (2025-002)

Material Weakness 2025

Ecorse Public Schools

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments...

Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments to discuss budget performance and funding compliance.

View Audit 375991

Finding 1165374 (2025-003)

Material Weakness 2025

Lawndale Christian Health Center and Affiliates

IL

Procurement, Suspension & Debarment § 200.212 § 200.318

Suspension and Debarment Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. Recommendation: We recommend that the organizatio...

Suspension and Debarment Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The organization did not document that Sam.gov was checked prior to entering into a contract with a vendor. Recommendation: We recommend that the organization retain documentation that Sam.gov was used to verify that a vendor was not suspended, debarred, or otherwise excluded from participating in the transaction prior to contract. To the extent practicable, the organization can engage with a third party that will verify any new and existing vendors have not been suspended or debarred on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management recognizes that even though none of the vendors utilized were suspended, debarred or otherwise excluded, the potential for violations increase if the verification is not done prior to engaging in transactions. For grant expenses with federal funding, LCHC management has implemented mandatory SAM.gov verification for all vendors prior to contract execution, with documentation retained in procurement files. LCHC has held meetings where applicable staff have been informed of compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025 If there are any questions regarding this plan, please call Jeffrey Nelson at 872-588-3033

View Audit 375978

Finding 1165373 (2025-002)

Material Weakness 2025

Lawndale Christian Health Center and Affiliates

IL

Procurement, Suspension & Debarment § 200.320

Procurement Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The Organization did not follow the procedures outlined within its internal policies related to maintaining documentation associated with purchases made via the simplifie...

Procurement Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Program – Assistance Listing No. 93.323 Condition: The Organization did not follow the procedures outlined within its internal policies related to maintaining documentation associated with purchases made via the simplified acquisition method of procurement. Recommendation: We recommend the organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management acknowledges that even though grant objectives were met, procurement procedures must be followed regardless of timeline constraints. Management has implemented enhanced controls to ensure compliance with internal procurement policies, including: (1) mandatory documentation for simplified acquisitions requiring evidence of price reasonableness; (2) staff meetings on procurement requirements; and (3) supervisory review of procurement files prior to grant invoice submission. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Nelson Planned completion date for corrective action plan: 7/1/2025

View Audit 375978

Finding 1165372 (2025-001)

Material Weakness 2025

Breckinridge-Grayson Programs, Inc.

KY

Reporting § 200.512 § 200.520

The Company will work with the audit firm to ensure the data collection form is filed timely in the future. The late filing was an oversight as the single audit package was not filed within 30 days after the receipt of the audit report, but prior to the nine-month deadline of February 28, 2025. Anti...

The Company will work with the audit firm to ensure the data collection form is filed timely in the future. The late filing was an oversight as the single audit package was not filed within 30 days after the receipt of the audit report, but prior to the nine-month deadline of February 28, 2025. Anticipate completion by 12/31/2025.

View Audit 375974

Finding 1165371 (2025-001)

Material Weakness 2025

Bonita Unified School District

CA

Internal Control / Segregation of Duties

We agree with the auditor’s comments and the following actions will be taken to ensure that graduation cohort data is maintained accurately: 1. When a student withdraws from one of our high schools, registrars will maintain accurate records in our SIS (Student Information System) and remove this stu...

We agree with the auditor’s comments and the following actions will be taken to ensure that graduation cohort data is maintained accurately: 1. When a student withdraws from one of our high schools, registrars will maintain accurate records in our SIS (Student Information System) and remove this student from our graduation cohort. 2. District office will assist registrars in contacting students who have withdrawn and ensure that forwarding information for next school of record is attained. These steps will allow us to maintain an accurate data base and records, including the graduation cohort.

View Audit 375972

Finding 1165369 (2025-003)

Material Weakness 2025

Platte Health Center

SD

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: As of June 30, 2025 management did not perform the proper calculations for the debt service coverage ratio in accordance with the commitm...

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: As of June 30, 2025 management did not perform the proper calculations for the debt service coverage ratio in accordance with the commitment letter. Additionally, the required debt service coverage ratio and required working capital amount were not presented to the board to ensure compliance is obtained. Responsible Individuals: Vicki Jensen, Chief Financial Officer Corrective Action Plan: The Platte Health Center will perform debt service ratio and working capital calculations, as required in the loan agreement. The calculations will be performed by the CFO as part of the year-end process. The CFO will provide a report to the Board of Directors and it will be noted in the official meeting minutes. Anticipated Completion Date: June 30, 2026.

View Audit 375939

Finding 1165331 (2025-001)

Material Weakness 2025

University of Cincinnati

OH

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s ...

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter

View Audit 375925

Finding 1165326 (2025-001)

Material Weakness 2025

Kanza Mental Health & Guidance Center, Inc.

KS

Procurement, Suspension & Debarment

Management’s Response/Corrective Action Plan (Unaudited): Management concurs with the finding. While procedures for verifying vendor eligibility are in place, KANZA acknowledges that documentation of suspension and debarment checks was not consistently retained during the audit period. Management re...

Management’s Response/Corrective Action Plan (Unaudited): Management concurs with the finding. While procedures for verifying vendor eligibility are in place, KANZA acknowledges that documentation of suspension and debarment checks was not consistently retained during the audit period. Management recognizes the importance of maintaining complete and verifiable documentation in accordance with federal procurement requirements. KANZA will implement the following actions to remediate the identified deficiency and strengthen compliance with suspension and debarment regulations: 1. Revision of Internal Procedures: Procurement policies will be updated to explicitly require suspension and debarment verification for all vendors prior to engagement and annually thereafter. Verification will be completed through SAM.gov. 2. Standardized Documentation Protocol: A standardized verification form will be implemented and required for all vendor files. The form will document the verification method, date, and staff member responsible. 3. Centralized Tracking and Monitoring: KANZA will maintain a centralized log of all suspension and debarment verifications. The log will be reviewed quarterly by the Director of Operations to ensure compliance with established procedures. 4. Staff Training: All staff involved in procurement, purchasing, and vendor management will receive training on suspension and debarment requirements and documentation standards. Training completion will be recorded. 5. Internal Compliance Reviews: Semiannual reviews of vendor files will be conducted to confirm the presence and completeness of required verification documentation. Corrective measures will be taken immediately for any identified deficiencies. Planned Completion Date: March 31, 2026 Contact Person Responsible for Correction Action: Shelby Donahoo, Director of Finance and Operations

View Audit 375917

Finding 1165325 (2025-003)

Material Weakness 2025

Rocky Mountain College

MT

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation ...

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation will now include evidence of rounding verification as part of the R2T4 process. Additionally, the Controller will obtain annual training on current Department of Education requirements, including proper rounding and calculation methodologies.

View Audit 375900

Finding 1165320 (2025-002)

Material Weakness 2025

Rocky Mountain College

MT

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility

Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline sh...

Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline shorter than the 14-day federal limit. Additionally, the CFO, Controller, and Student Accounts Coordinator will obtain training on the timing and documentation requirements under 34 CFR §668.164(h).

View Audit 375900

Finding 1165315 (2025-001)

Material Weakness 2025

Rocky Mountain College

MT

Reporting Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to moni...

Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to monitor and report student enrollment changes on a timely basis. The CFO, Controller, and Director of Student Records will explore enhanced monitoring controls such as designating a second reviewer to verify that all files were transmitted and accepted by NSC within required timeframes and implementing an internal tracking log to record the submission and confirmation dates for each roster file.

View Audit 375900

Finding 1165310 (2025-003)

Material Weakness 2025

Chatham School District

AK

Procurement, Suspension & Debarment Reporting Significant Deficiency

The District will stregthen controls to ensure all expenditures charged to federal programs are allowable, properly documented, and comply with the Uniform Guidance (2 CFR Part 200). 1. Policy and Procedure development: Written procedures will be implemented defining allowable costs, budget approval...

The District will stregthen controls to ensure all expenditures charged to federal programs are allowable, properly documented, and comply with the Uniform Guidance (2 CFR Part 200). 1. Policy and Procedure development: Written procedures will be implemented defining allowable costs, budget approval processes, and documentation requirements for federal programs. 2. Pre-approval and Documentation: All expenditures charged to federal awards must receive prior approval from the Program Director and Business Manager, accompanied by invoices, purchase orders, and justification forms referencing the applicable federal cost principle. 3. Monthly Monitoring: The Business Manager will review program expenditures monthly for compliance with allowable cost principles and promptly correct any mischarges. 4. Training: Federal program staff and members of the CSG grants Committee will receive annual training on allowable costs, cost allocation, and time-and effort reporting.

View Audit 375895

Finding 1165309 (2025-001)

Material Weakness 2025

Romoland School District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue ...

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue to utilize the CalPads 1.17 report for reporting student counts for each school. Moving forward, we will implement a dual-verification process, requiring a second person to confirm data accuracy during the entry of numbers into CARS, thereby mitigating the risk of future data entry errors.

View Audit 375893

Finding 1165305 (2025-001)

Material Weakness 2025

Whitehall District Schools

MI

Allowable Costs / Cost Principles Reporting Cash Management § 200.430

Finding 2025-001: Head Start Cluster Semi-Annual Certification Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Number: 93.600 Award numbers: 05CH011882-04, 05CH011882-05 Award year ends: November 30, 2024 and N...

Finding 2025-001: Head Start Cluster Semi-Annual Certification Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Number: 93.600 Award numbers: 05CH011882-04, 05CH011882-05 Award year ends: November 30, 2024 and November 30, 2025 Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for verifying program employee listings are complete under Uniform Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Action Taken: The Business Manager will provide semi-annual certification templates to all program directors. The Business Manager and program directors will review staff listings together to ensure all necessary employees are listed. Training on the certification process will be provided to all directors of federally funded programs. All federally funded salaried employees are required to complete certifications twice each year. The first submission is due to the Business Manager by January 15, and the second is due by July 15. The Business Manager will verify and maintain all certification records. Responsible Person and Anticipated Completion Date: Business Manager, November 2025 If the Michigan Department of Education has questions regarding this plan, please call CJ Van Wieren at (231) 893-1005.

View Audit 375856

Finding 1165302 (2025-001)

Material Weakness 2025

Housing Authority of Lake City

SC

HUD Housing Programs Allowable Costs / Cost Principles Cash Management

2025-001 ALN 14.871 – Housing Voucher Cluster – Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Colu...

2025-001 ALN 14.871 – Housing Voucher Cluster – Activities Allowed or Unallowed The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Questioned Costs. In 2021, the Authority was instructed by Keith Landrum of the Columbia, South Carolina HUD Field Office to stop making payments until the matter could be further investigated to see what amounts, if any, are still owed. Management will continue to monitor budgets to ensure that funds are adequate. Management has and will continue to make budget revisions to reduce unessential operating costs. The Authority has designed and implemented a Board approved formal repayment agreement. Person Responsible for Correction of Finding: Mark Fountain, Executive Director Projected Completion Date: June 30, 2026

View Audit 375853

Finding 1165301 (2025-001)

Material Weakness 2025

Sterling Community Unit School District No. 5

IL

Cash Management Reporting Internal Control / Segregation of Duties

Condition: During audit fieldwork, our testing resulted in a restatement of fund balance in order to correct categories of capital assets that were improperly recorded in prior years. Plan: The District will implement internal controls to properly record capital assets on a timely basis prior to aud...

Condition: During audit fieldwork, our testing resulted in a restatement of fund balance in order to correct categories of capital assets that were improperly recorded in prior years. Plan: The District will implement internal controls to properly record capital assets on a timely basis prior to audit fieldwork. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Matt Birdsley, Director of Finance/CSBO Management Response: The District will implemented controls to more accurately track construction in progress and record it correctly within our system to report accurately. In some cases, the contractors have submitted payment without accurately indicating the fiscal year the work was completed. For this, the district will assign the appropriate amount of the work to the appropriately fiscal year when receiving the pay applications.

View Audit 375850

Finding 1165298 (2025-001)

Material Weakness 2025

Somerville Housing Authority

MA

HUD Housing Programs

Finding 2025-001 – Housing Choice Voucher Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster – ALNs 14.871 and 14.879 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority’s Single Audit ...

Finding 2025-001 – Housing Choice Voucher Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster – ALNs 14.871 and 14.879 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority’s Single Audit for the year ended March 31, 2025, indicating that SHA received a finding of Significant Deficiencies. Auditors identified four instances of miscalculated income, two instances of missing or improper income verification, two instances of missing or improper deduction verification, and six instances in which the EIV report was not maintained in the tenant file. Extrapolation of errors to the population found the potential misstatement to be immaterial to program HAP expense. Auditors note that all income-related discrepancies were found in files selected from a HAP register dated earlier in the fiscal year, indicating improvements in compliance as the year progressed. Auditors recommend that SHA should continue to monitor areas and strengthen controls pertaining to income verification, calculation, and documentation retention to promote continued improvement and prevent recurrence of similar issues PHA Response: The SHA has implemented a corrective action plan to address noted deficiencies. The SHA has had significant staffing turnover in the last year. While vacant positions were filled, the SHA contracted with Nan McKay Associates (NMA) to complete all Annual Recertifications. NMA assigned four full-time staff to complete all recertifications and assigned one additional full-time staff person to conduct a monthly Qualify Control Review of all recertifications completed by NMA. During NMA’s contract, SHA focused on hiring and training new staff. SHA has hired a new Director of Leased Housing, a new Leased Housing Supervisor, three Leasing Coordinators, and a Tenant Selector. The Director and Supervisor have been providing one-on-one training and support. New staff have also been enrolled in training opportunities provided by outside vendors such as the Nan McKay Rent Calculation Class. As of 7/31/2024, SHA has resumed program management from NMA. SHA has also increased the agency’s internal quality control audits. The Director of Leased Housing has increased monthly SEMAP review from 40 to 50 files. Monthly feedback is provided to staffers individually and systemic issues are addressed to the entire department. The Supervisor also conducts a monthly review of the Income Verification Tool, following up with staffers to assist them in addressing discrepancies with their client’s records. Additionally, SHA has fully implemented an electronic file storage system, utilizing PHA Web’s online system to better organize, track, and maintain client files. Since implementation of the corrective action plan, 99% of reviewed files were found to have appropriate Payment Standards, 97% have appropriate third party documentation, and 94% have appropriate adjusted income. 97% were found to have appropriate Utility Allowances. Corrective action has been taken on all errors, and guidance has been provided to staff. SHA will continue conducting file audits, as well as following up with staff. PHA Goal: Based on the SHA’s monthly quality control sample of tenant files: (A) The SHA obtains third party verification of reported family annual income, the value of assets totaling more than $5,000, expenses related to deductions from annual income, and other factors that affect the determination of adjusted income, and uses the verified information in determining adjusted income, and/or documents tenant files to show why third party verification was not available; (B) The SHA properly attributes and calculates allowances for any medical, child care, and/or disability assistance expenses; and (C) The SHA uses the appropriate utility allowances to determine gross rent for the unit leased, (D) The SHA applies the appropriate payment standard in accordance with 24 CFR 982.505. PHA Strategies: Target Completion Date: 1) The SHA will review its current quality control tracking system to record the results of random sampling of files as required in 985.2. The SHA will revise this system on an ongoing basis if necessary. 3/31/2026 2) Confirm that 90% or more files sampled contain proper third party written verification (or equivalent) of income and assets, proper calculation of appropriate deductions and allowances and that appropriate utility allowance were used in the calculation of tenant rent. 3/31/2026 Persons Responsible: Matt Lincoln, Director of Leased Housing David Hospedales, Leased Housing Supervisor

View Audit 375845

Finding 1165296 (2025-003)

Material Weakness 2025

Somerville Housing Authority

MA

HUD Housing Programs Eligibility

Finding 2025-003 – Section 8 Project-Based Cluster Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster – ALNs 14.195 and 14.249 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority’s Sing...

Finding 2025-003 – Section 8 Project-Based Cluster Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster – ALNs 14.195 and 14.249 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority’s Single Audit for the year ended March 31, 2025, indicating that SHA received a finding of Significant Deficiencies. Auditors identified two files missing proper income verification, and seven files missing the EIV report. Extrapolation of errors to the population found the potential misstatement to be immaterial to program HAP expense. Auditors note that all income-related discrepancies were found in files selected from a HAP register dated earlier in the fiscal year, indicating improvements in compliance as the year progressed. Auditors recommend that SHA should enhance its quality control procedures to ensure compliance with HUD income verification regulations and EIV review requirements. Regular internal reviews and staff training should be conducted t oaddress these compliance issues effectively. PHA Response: The SHA has implemented a corrective action plan to address noted deficiencies. The SHA has had significant staffing turnover in the last year. While vacant positions were filled, the SHA contracted with Nan McKay Associates (NMA) to complete all Annual Recertifications. NMA assigned four full-time staff to complete all recertifications and assigned one additional full-time staff person to conduct a monthly Qualify Control Review of all recertifications completed by NMA. During NMA’s contract, SHA focused on hiring and training new staff. SHA has hired a new Director of Leased Housing, a new Leased Housing Supervisor, three Leasing Coordinators, and a Tenant Selector. The Director and Supervisor have been providing one-on-one training and support. New staff have also been enrolled in training opportunities provided by outside vendors such as the Nan McKay Rent Calculation Class. As of 7/31/2024, SHA has resumed program management from NMA. SHA has also increased the agency’s internal quality control audits. The Director of Leased Housing has increased monthly SEMAP review from 40 to 50 files. Monthly feedback is provided to staffers individually and systemic issues are addressed to the entire department. The Supervisor also conducts a monthly review of the Income Verification Tool, following up with staffers to assist them in addressing discrepancies with their client’s records. Additionally, SHA has fully implemented an electronic file storage system, utilizing PHA Web’s online system to better organize, track, and maintain client files. Since implementation of the corrective action plan, 97% of reviewed files have appropriate third party documentation, 94% have appropriate adjusted income, and 97% were found to have appropriate Utility Allowances. Corrective action has been taken on all errors, and guidance has been provided to staff. SHA will continue conducting file audits, as well as following up with staff. PHA Goal: Based on the SHA’s monthly quality control sample of tenant files: (A) The SHA obtains third party verification of reported family annual income, the value of assets totaling more than $5,000, expenses related to deductions from annual income, and other factors that affect the determination of adjusted income, and uses the verified information in determining adjusted income, and/or documents tenant files to show why third party verification was not available; (B) The SHA properly attributes and calculates allowances for any medical, child care, and/or disability assistance expenses; and (C) The SHA uses the appropriate utility allowances to determine gross rent for the unit leased in accordance with 24 CFR 982.505. PHA Strategies: Target Completion Date: 1) The SHA will review its current quality control tracking system to record the results of random sampling of files as required in 985.2. The SHA will revise this system on an ongoing basis if necessary. 3/31/2026 2) Confirm that 90% or more files sampled contain proper third party written verification (or equivalent) of income and assets, proper calculation of appropriate deductions and allowances and that appropriate utility allowance were used in the calculation of tenant rent. 3/31/2026 Persons Responsible: Matt Lincoln, Director of Leased Housing David Hospedales, Leased Housing Supervisor

View Audit 375845

Finding 1165294 (2025-002)

Material Weakness 2025

Somerville Housing Authority

MA

HUD Housing Programs

Finding 2025-002 – Low Rent Public Housing Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Low Rent Public Housing – ALN 14.850 Condition & Cause: Our review of thirty (30) Low Rent Public Housing tenant files identified noncompliance in twelve (12) files within...

Finding 2025-002 – Low Rent Public Housing Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Low Rent Public Housing – ALN 14.850 Condition & Cause: Our review of thirty (30) Low Rent Public Housing tenant files identified noncompliance in twelve (12) files within one or more categories. Of these, eight (8) files, or roughly 26%, were for the determination of adjusted annual income. Specifically, we noted the following: • Three (3) files were missing proper income verification • Three (3) files included income miscalculations • Two (2) files lacked required documentation to support deductions • Five (5) units did not have evidence of an annual inspection on file Based on extrapolation of these errors to the population, we identified likely questioned costs totaling $134,699, representing approximately 3.25% of total dwelling rental income. We also observed that the Public Housing department operated with significant staffing shortages for much of the fiscal year, which likely contributed to these deficiencies. PHA Response: The SHA has reviewed these deficiencies with the responsible staff members. Public housing staff have received internal training on required and acceptable income and deduction verifications and subsequent calculations. A file integrity checklist has been created for housing managers to ensure all required forms, calculations and required support is included and accurate. Further, internal file review procedures will be established in the current fiscal year. File integrity reviews will be performed by the Division Director and SHA is also exploring the value of peer reviews between housing managers and support staff. Internal inspection processes have also been improved. SHA has created a new Director of Operations position that is responsible for oversight and scheduling of inspections. This will provide more direct oversight of unit inspections and ensure that all annual and other inspections are performed timely and resulting reports are provided to the housing manager for the resident file. Persons Responsible: Lisa Taylor, Director of Admissions, Occupancy and Compliance Anticipate Completion Date: March 31, 2026

View Audit 375845

Finding 1165293 (2025-003)

Material Weakness 2025

Mount Saint Mary's University

CA

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-003 Condition: The University did not have updated procedures and processes in place specific to all the required GLBA elements. The GLBA policy review and updates are still in process. Corrective Acti...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-003 Condition: The University did not have updated procedures and processes in place specific to all the required GLBA elements. The GLBA policy review and updates are still in process. Corrective Action Plan: Due to the transition within the institution’s information security department, the University is still in the process of updating its information security policy and framework and will have these approved in fiscal year 2026. The University is continuing to work on implementing the remaining elements of the GLBA requirements and has been tracking and monitoring its progress. Name(s) of Contact Person(s) Responsible for Corrective Action: Jamal Nasser, Chief Information Officer Anticipated Completion Date: June 30, 2026 Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165288 (2025-002)

Material Weakness 2025

Mount Saint Mary's University

CA

Student Financial Aid Reporting Significant Deficiency

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corre...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corrective Action Plan : The Registrar’s office generates enrollment reports every three (3) weeks and they are sent to NSLDS. These reports allow for frequent degree of enrollment reporting to correct this type of error. These changes are in place and have taken effect immediately. Name(s) of Contact Person(s) Responsible for Corrective Action: Rocio De Leon, Registrar Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165283 (2025-001)

Material Weakness 2025

Mount Saint Mary's University

CA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will co...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will continue to review and adhere to our procedures for refunding awards, and the Financial Aid office will formally document the weekly review of the Return of Title IV funds. Name(s) of Contact Person(s) Responsible for Corrective Action: La Royce Housley, Director of Financial Aid Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165276 (2025-001)

Material Weakness 2025

Littlefield Isd

TX

§ 200.320

The District will develop and implement a formal procurement checklist. This checklist will be completed by the Business Manager for all purchases expected to exceed the micro-puchase threshold. The procedure will require the checklist to be completed and attached to the purchase order before the pu...

The District will develop and implement a formal procurement checklist. This checklist will be completed by the Business Manager for all purchases expected to exceed the micro-puchase threshold. The procedure will require the checklist to be completed and attached to the purchase order before the purchase is finalized, ensuring and documenting that the required price of rate quotations have been obtained in accordance with 2 CFR section 200.320.

View Audit 375792

Finding 1165272 (2025-001)

Material Weakness 2025

South Carolina Victim Assistance Network

SC

HUD Housing Programs

The duties will be segregated as much as possible and the Board of Directors will remain involved in the financial affairs of the Network to provide oversight and independent review functions.

View Audit 375776

Corrective Action Plans

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