Corrective Action Plans

Finding 1157314 (2024-002)

Material Weakness 2024

PA

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403

Finding 2024-002 – Material Weakness – Inadequate Documentation Condition We selected a sample of both payroll and nonpayroll related expenditures for controls and compliance. During our testing of payroll expenditures, there were five instances out of 11 in which a timesheet or other documentation ...

Finding 2024-002 – Material Weakness – Inadequate Documentation Condition We selected a sample of both payroll and nonpayroll related expenditures for controls and compliance. During our testing of payroll expenditures, there were five instances out of 11 in which a timesheet or other documentation could not be located to support a payment made to an employee. During our testing of nonpayroll related expenditures, there were three instances out of 18 in which an invoice for the selected expenditure lacked proper documented approvals. Recommendation All employees in the Finance Department and associated with any federal program must be adequately trained in overall federal regulations and guidance as well as other requirements associated with each federal award. All such employees must read the grant-related policies and internal control policies. Management should check to ensure all federal grant expenditures are properly approved and have supporting documentation. Management’s Corrective Action Plan The Corporation has experienced staff turnover which resulted in process challenges. Nevertheless, the Corporation will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Corporation resources receive federal regulations and guidance training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. Contact Person: Richonda Pelzer, Chief Financial Officer Anticipated Completion Date: March 31, 2026

View Audit 369593 Questioned Costs: $1

Finding 1157312 (2024-001)

Material Weakness 2024

Impact Services Corporation

PA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Material Weakness § 200.512

Finding 2024-001 – Material Weakness – Accounting Discipline and Recordkeeping Condition During the audit of the fiscal year ending June 30, 2024, Impact Services Corporation and Affiliates‘ (the “Corporation's”) management was unable to provide timely year-end trial balances in accordance with U.S....

Finding 2024-001 – Material Weakness – Accounting Discipline and Recordkeeping Condition During the audit of the fiscal year ending June 30, 2024, Impact Services Corporation and Affiliates‘ (the “Corporation's”) management was unable to provide timely year-end trial balances in accordance with U.S. GAAP. An accurate year-end trial balance was not provided in a timely manner, and management continued to make a significant number of adjustments after the year-end trial balance had been provided to the auditors, resulting in significant time by management and the auditors to complete the audit. As a result, the fiscal year 2024 financial statements were not finalized in time to meet the deadlines noted in 2 CFR Section 200.512(a)(1). In addition, during the audit it was discovered that certain account balances and transactions were not properly recorded in the prior year, resulting in a prior period adjustment to correct the beginning balances as of July 1, 2023. While reconciling accounts payable and accrued expenses as of June 30, 2024, management discovered that the accounts payable balance was incorrect dating back to 2023. The Corporation changed accounting software packages during the year ended June 30, 2023 and during the transition of accounting packages, an accounts payable balance totaling $390,229 transferred into the new software. The invoices representing this balance were also entered into the accounts payable module and transferred into the general ledger module, resulting in a double recording of the accounts payable balance and overstatement of expenses by $390,229 in fiscal year 2023. Recommendation We recommend that management continue to review and update the Corporation's policies and procedures to ensure that the trial balance is accurate throughout the year. Account reconciliations and supporting schedules should be prepared and reviewed on a monthly basis. The accounting books and records should be closed timely at year end and thoroughly reviewed. Management’s Corrective Action Plan In February 2025, a new Chief Financial Officer was hired and immediately launched a full evaluation of the Accounting and Finance department. Her efforts have included restructuring staff, restarting the fiscal year 2024 audit, implementing new financial policies, and launching a credit card purchasing system with embedded controls. Within six months, she has established new internal controls, enhanced financial reporting, and introduced staff training protocols. To remediate the material weakness, the Corporation has implemented the following initiatives: • Month-End Close Process: July 2025 marked the first successful month-end close, anticipated to be completed on August 22, 2025. This included key reconciliations, journal entries, and revenue-expense reporting. • Department Structure and Documentation: We are refining processes and documentation using technology and talent to promote transparency and accountability. • Leveraging Technology: o Ramp: Enables real-time spend controls, customizable virtual cards, and automated receipt matching. It enforces policy compliance, prevents unauthorized purchases, and supports audit readiness. o NetSuite ERP: Streamlines operations and decision-making through automated, real-time reporting, ensuring consistent and accurate insights across departments. We affirm our alignment with the auditor's recommendations to ensure trial balance accuracy, monthly account reconciliations, and timely year end closings. These practices are now embedded in our financial operations and supported by enhanced review protocols. The Corporation is confident that these corrective actions will fully address the material weakness and position the Corporation for sustained financial health, transparency, and compliance. Contact Person: Richonda Pelzer, Chief Financial Officer Anticipated Completion Date: March 31, 2026

View Audit 369593

Finding 1157294 (2024-001)

Material Weakness 2024

Town of Southold

NY

Subrecipient Monitoring § 200.332

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

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

View Audit 369589

Finding 1157287 (2024-003)

Material Weakness 2024

Fort Worth Housing Solutions

TX

HUD Housing Programs

Significant Deficiency in Internal Control over Compliance, Other Matters – Annual HQS Inspection Housing Choice Voucher Program – Assistance Listing No. 14.871 – HQS Enforcement Recommendation: We recommend that the Authority implement processes to ensure that inspections are completed on time. Exp...

Significant Deficiency in Internal Control over Compliance, Other Matters – Annual HQS Inspection Housing Choice Voucher Program – Assistance Listing No. 14.871 – HQS Enforcement Recommendation: We recommend that the Authority implement processes to ensure that inspections are completed on time. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has implemented enhanced procedures to ensure timely completion of Housing Quality Standards (HQS) inspections. A scheduling and tracking system has been established to monitor upcoming inspections, and staff have been trained on these updated procedures. Additionally, the HCV supervisor conducts weekly reviews to ensure inspections are completed on schedule and any delays are addressed promptly. Name(s) of the contact person(s) responsible for corrective action: Lanesha Combs, Vice President of Housing Choice Voucher Program Planned completion date for corrective action plan: December 31, 2025 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Hector Ordonez, Vice President of Finance and Administration at (817) 333-3421 or hordonez@fwhs.org.

View Audit 369582

Finding 1157286 (2024-002)

Material Weakness 2024

Fort Worth Housing Solutions

TX

HUD Housing Programs

Significant Deficiency in Internal Control over Compliance, Other Matters – Rent Reasonableness Housing Choice Voucher Program – Assistance Listing No. 14.871 - Rent Reasonableness Recommendation: We recommend that the Authority implement processes to ensure that rent reasonableness determinations a...

Significant Deficiency in Internal Control over Compliance, Other Matters – Rent Reasonableness Housing Choice Voucher Program – Assistance Listing No. 14.871 - Rent Reasonableness Recommendation: We recommend that the Authority implement processes to ensure that rent reasonableness determinations are completed on time. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has strengthened its internal controls to ensure timely completion of rent reasonableness determinations. We will implement a tracking process in the department to flag upcoming rent reasonableness reviews before the deadline. Staff have been trained on the updated procedures, and a monthly compliance review will be conducted by the HCV supervisor to verify that all determinations are completed on time and documented appropriately. Name(s) of the contact person(s) responsible for corrective action: Lanesha Combs, Vice President of Housing Choice Voucher Program Planned completion date for corrective action plan: December 31, 2025

View Audit 369582

Finding 1157285 (2024-001)

Material Weakness 2024

Fort Worth Housing Solutions

TX

Reporting Matching / Level of Effort / Earmarking § 200.302 § 200.303

Significant Deficiency in Internal Control over Compliance, Other Matters U.S. Department of the Treasury U.S. Department of Housing and Urban Development Coronavirus State and Local Fiscal Recovery Funds Community Development Block Grants/Entitlement Grants 21.027 14.218 Recommendation: We recommen...

Significant Deficiency in Internal Control over Compliance, Other Matters U.S. Department of the Treasury U.S. Department of Housing and Urban Development Coronavirus State and Local Fiscal Recovery Funds Community Development Block Grants/Entitlement Grants 21.027 14.218 Recommendation: We recommend that the Authority implements controls to ensure that the preliminary SEFA is mostly accurate so that the correct programs are tested. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Finance Department has implemented several processes and procedures to ensure pass-through funds or sub-awards are reported timely and accurately in the SEFA. The new processes include (1) review of grant award letters to determine reporting requirements, (2) comparing the award letter against the Minutes of the City Council or County Commissioners meetings to ensure grants accepted during the year are disclosed as such on both ends, (3) confirmed with source Agency Single Audit requirements, (4) and the implementation of revenue source checklist that will identify the source of the funds, type of grant, program name and cluster title, name of federal funding agency, federal assisting listing number (formerly known as CFDA number), etc. Name(s) of the contact person(s) responsible for corrective action: Hector Ordonez, Vice President of Finance and Administration Planned completion date for corrective action plan: December 31, 2025 Name(s) of the contact person(s) responsible for corrective action: Hector Ordonez, Vice President of Finance and Administration Planned completion date for corrective action plan: December 31, 2025

View Audit 369582

Finding 1157284 (2024-002)

Material Weakness 2024

Pierce Mortuary Colleges, Inc.

IL

Student Financial Aid Subrecipient Monitoring Reporting

Actions Taken: The institution has implemented an automated process for Exit Counseling to ensure compliance with Title IV requirements. As of August 2025, the system has been configured to automatically send an exit counseling notification to students when they enter one of the following statuses: ...

Actions Taken: The institution has implemented an automated process for Exit Counseling to ensure compliance with Title IV requirements. As of August 2025, the system has been configured to automatically send an exit counseling notification to students when they enter one of the following statuses: • Withdrawal • Graduation • Less than half-time enrollment System Workflow: When a student’s status changes, the system immediately generates and sends an email alert containing exit counseling instructions and the necessary links for completion. This ensures timely notification without requiring manual tracking by staff. Monitoring and Compliance: • Reports will be reviewed monthly to confirm that all required students received the exit counseling notifications. • Any discrepancies will be immediately investigated and resolved. Outcome: This automation eliminates the manual process previously in place, ensuring 100% notification compliance and greatly reducing the likelihood of future deficiencies in this area.

View Audit 369581

Finding 1157283 (2024-001)

Material Weakness 2024

Pierce Mortuary Colleges, Inc.

IL

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Actions Taken / Planned The institution recognizes the importance of timely processing of Title IV credit balances and refunds. To address the deficiencies identified: 1. Short-Term Action (Current Practice): Effective immediately, all staff are required to submit for processing refunds within 24 ho...

Actions Taken / Planned The institution recognizes the importance of timely processing of Title IV credit balances and refunds. To address the deficiencies identified: 1. Short-Term Action (Current Practice): Effective immediately, all staff are required to submit for processing refunds within 24 hours of identifying a credit balance. Staff will also promptly correct any errors discovered during the reconciliation process. o Monitoring: Supervisors will conduct weekly reviews to ensure compliance with this 24-hour policy. o Training: Refresher training on Title IV credit balance processing has been provided to all relevant staff as of September 2025. o Instead of one ‘check run’ per week, numerous ‘check runs’ may be necessary to ensure 14 day window is met. 2. Long-Term Action (System Integration and Automation): The institution is actively working to integrate QuickBooks into our Student Information System (SIS) to automate Title IV and refund documentation. o This integration will streamline the reconciliation process, reduce manual errors, and ensure consistent, timely processing of refunds. o Projected Completion Date: Implementation and full automation are expected to be completed within 9–12 months, with a target date of September 2026. Expected Outcome: These measures will ensure timely and accurate processing of Title IV credit balances, improve compliance, and reduce the risk of future findings.

View Audit 369581

Finding 1157281 (2024-002)

Material Weakness 2024

The Arc of Delaware

DE

HUD Housing Programs Special Tests & Provisions Allowable Costs / Cost Principles

Corrective Action Plan: The ARC of Delaware will ensure that there are appropriate procedures in place to ensure that the required calculation of surplus cash is completed with 60-days of year end. ARC of Delaware will also ensure that individuals have appropriate access to HUD Reporting tools to en...

Corrective Action Plan: The ARC of Delaware will ensure that there are appropriate procedures in place to ensure that the required calculation of surplus cash is completed with 60-days of year end. ARC of Delaware will also ensure that individuals have appropriate access to HUD Reporting tools to ensure timely calculation. Contact Person Responsible for Correction Action: Stanley Kihara, Controller Completion Date:

View Audit 369576

Finding 1157263 (2024-001)

Material Weakness 2024

The Arc of Delaware

DE

HUD Housing Programs Special Tests & Provisions § 200.303

Corrective Action Plan: The ARC of Delaware will update monthly replacement reserve deposit amounts upon notification from HUD. The Arc will perform an analysis every 30 days to ensure deposits have been made for the appropriate amount. ARC completed this corrective action plan when it was notified ...

Corrective Action Plan: The ARC of Delaware will update monthly replacement reserve deposit amounts upon notification from HUD. The Arc will perform an analysis every 30 days to ensure deposits have been made for the appropriate amount. ARC completed this corrective action plan when it was notified during the prior period single audit. Contact Person Responsible for Correction Action: Stanley Kihara, Controller Completion Date: July 15, 2024

View Audit 369576

Finding 1157245 (2024-002)

Material Weakness 2024

Lebanon County Conservation District

PA

Procurement, Suspension & Debarment

The Conservation District agrees with the finding and has implemented procedures to ensure all future vendor contracts are not suspended and debarred prior to contracting with them.

View Audit 369568

Finding 1157240 (2024-001)

Material Weakness 2024

Essex-Newark Legal Services Project, Inc.

NJ

Reporting Allowable Costs / Cost Principles Material Weakness

Internal Control over Compliance and Other Matters Recommendation: We recommend that the Organization implement adequate controls to ensure the timely submission of the required granter reports. If delays, with the submission of a report, occur, we recommend that the Organization notifies its grante...

Internal Control over Compliance and Other Matters Recommendation: We recommend that the Organization implement adequate controls to ensure the timely submission of the required granter reports. If delays, with the submission of a report, occur, we recommend that the Organization notifies its granter and obtains an extension of the report due date. There is no disagreement with the audit finding. Action planned in response to finding: Essex-Newark Legal Services Project, Inc agrees that it will timely advise granters when a delay in the timely submission of a report is anticipated. Name of the contact person responsible for corrective action: Felipe Chavana, Executive Director Planned completion date for corrective action plan: Effectively Immediately.

View Audit 369565

Finding 1157239 (2024-005)

Material Weakness 2024

County of Alpena, Michigan

MI

Reporting Internal Control / Segregation of Duties § 200.303 § 200.510

Corrective Action Plan: The County has agreed to strengthen internal controls through regular reconciliations between project managers and the Clerk’s office to ensure timely reporting, submission for reimbursement and inclusion on the financial statements. Responsible Party: Alpena County Treasurer...

Corrective Action Plan: The County has agreed to strengthen internal controls through regular reconciliations between project managers and the Clerk’s office to ensure timely reporting, submission for reimbursement and inclusion on the financial statements. Responsible Party: Alpena County Treasurer and Alpena County Administrator Date of Planned Corrective Action: July 1, 2025 Management Assessment: We concur with the audit assessment regarding this matter.

View Audit 369562

Finding 1157238 (2024-001)

Material Weakness 2024

Greenwich Communities (f/ka)housing Authority of the Town of Greenwich

CT

HUD Housing Programs

Greenwich Communities' Response This finding is mainly due to delays in the processing/payment of utility invoices which was in part attributed to staff shortage in accounts payable and increase in the number of properties under management, whereby the volume of utility invoices increased. In August...

Greenwich Communities' Response This finding is mainly due to delays in the processing/payment of utility invoices which was in part attributed to staff shortage in accounts payable and increase in the number of properties under management, whereby the volume of utility invoices increased. In August 2024, we hired an accountant where his responsibilities include the accounting for utility expenses. We have implemented additional procedures to straighten utility processing to ensure invoices are processed/paid timely including a process to maintain monthly analysis of utility expenses to track invoices and to ensure invoices are processed timely and/or accrued. We also perform variance analysis of expenses whereby significant variations are investigated and resolved. Effective for 2024/2025 utility cost reporting, we have implemented a robust review process whereby the utility cost reports will be prepared by the staff accountant, reviewed by the Controller with final approval by the Chief Financial Officer. We understand that given the timing, this may be a repeat finding for fiscal year December 31, 2025.

View Audit 369561

Finding 1157237 (2024-001)

Material Weakness 2024

Greeley-Weld County Airport Authority

CO

Reporting

The Airport has coordinated with the FAA Airport District Offic Planner and will submit the outstanding SF-425 for the grants open as of 12/31/2024 upon project close out in 2025. Going forward, SF-425 reports will be filed annually by December 31st for all open grants. The Business Manager and Airp...

The Airport has coordinated with the FAA Airport District Offic Planner and will submit the outstanding SF-425 for the grants open as of 12/31/2024 upon project close out in 2025. Going forward, SF-425 reports will be filed annually by December 31st for all open grants. The Business Manager and Airport Director will mainain a compliance calendar to ensure timely submission of future reports.

View Audit 369560

Finding 1157234 (2024-001)

Material Weakness 2024

Ellwood City Borough

PA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.303

CONDITION: During my review of the Borough of Ellwood City’s internal controls over federal awards, I noted that the Borough does not have formal written policies and procedures surrounding the management of their federal award funds. Although not all-inclusive, an example of some of the required po...

CONDITION: During my review of the Borough of Ellwood City’s internal controls over federal awards, I noted that the Borough does not have formal written policies and procedures surrounding the management of their federal award funds. Although not all-inclusive, an example of some of the required polices would include written procedures for procurement, conflict of interest, and allowable costs. This is a repeat finding (2023-001) from the prior year.CRITERIA: Section 2 CFR 200.303 of the Uniform Guidance requires non-federal entities such as the Borough of Ellwood City to maintain effective internal controls over federal awards. In addition, the Uniform Guidance also recommends these internal controls follow guidance in Standards for Internal Control in the Federal Government (the Green Book), issued by the Comptroller General of the United States.RECOMMENDATION: I recommend that the Borough of Ellwood City adopt the required written policies and procedures surrounding the management of federal award funds as prescribed by Section 2 CFR 200.303 of the Uniform Guidance. The focus of these policies and procedures should be to ensure that the Borough officials who are responsible for carrying out the objectives of the federal financial award understand 1) the federal statutes, regulations, and terms and conditions of the award, 2) how to evaluate and properly monitor compliance, and 3) the steps to take if noncompliance is identified.MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the Borough will begin the process of reviewing Section 2 CFR 200.303 of the Uniform Guidance with the objective of understanding what specific policies and procedures surrounding the management of their federal award funds are required. As recommended, the focus of these policies and procedures will be to ensure that the Borough officials who are responsible for carrying out the objectives of the federal financial award understand 1) the federal statutes, regulations, and terms and conditions of the award, 2) how to evaluate and properly monitor compliance, and 3) the steps to take if noncompliance is identified. The timeframe for researching the required written policies and procedures of the Uniform Guidance, and the development and implementation of these written policies and procedures will cover the period including the last quarter of calendar year 2025 through and including the 2nd quarter of calendar year 2026.Borough Officials responsible for the implementation of the Corrective Action Plan:Kevin Swogger, Borough Manager.

View Audit 369555

Finding 1157232 (2024-001)

Material Weakness 2024

Town of Clarkstown

NY

Reporting § 200.512

the Town has recently hired a new Cmptroller who will be overseeing all internal financial controls and processes, including the supervsion and preparation of timely annual SEFA reporting

View Audit 369549

Finding 1157231 (2024-001)

Material Weakness 2024

Glory Revealed Mission

MS

The Organization hired additional personnel along with additional controls implemented by management and supplemental reviews by members of the Board of Directors will increase separation of duties related to accounting functions.

View Audit 369548

Finding 1157230 (2024-001)

Material Weakness 2024

St John's Health Care Corporation

NY

HUD Housing Programs Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

September 29, 2025 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsfor...

September 29, 2025 U.S. Department of Housing and Urban Development St. John’s Health Care Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully’s Trail Pittsford, NY 14534 Audit Period: January 1, 2024 – December 31, 2024 The findings from the December 31, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD PROGRAMS AUDIT FINDING 2024-001: Section 232, CFDA 14.129 Recommendation: Adhere to the HUD regulatory agreement in relation to obtaining prior written approval from HUD before encumbering the Project. Action Taken: The Home obtained the additional related-party loan as a prudent business decision to meet operating expenses. The Home has implemented procedures to ensure that prior written approval is obtained from HUD before encumbering the Project in the future. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Sabrina McLeod at (585)-760-1401. Sincerely yours, _______________________________ Sabrina McLeod Chief Financial Officer

View Audit 369546

Finding 1157229 (2024-002)

Material Weakness 2024

Wellspring Family Services

WA

Special Tests & Provisions HUD Housing Programs Significant Deficiency

Contact Person(s): Calli Clevinger and Cobie Sparks-Howard Corrective Actions in Progress: 1. Policy Reinforcement: Staff will be re-trained on Wellspring’s rent reasonableness policy, with emphasis on the requirement to include comparable unit data on every form. 2. Integration with Move-In Assessm...

Contact Person(s): Calli Clevinger and Cobie Sparks-Howard Corrective Actions in Progress: 1. Policy Reinforcement: Staff will be re-trained on Wellspring’s rent reasonableness policy, with emphasis on the requirement to include comparable unit data on every form. 2. Integration with Move-In Assessment: The rent reasonableness form will now be a required document attached to the move-in assessment. A unit will not be approved for move-in until the rent reasonableness form is fully completed and attached. 3. Secondary Review: Supervisors will conduct a review of all move-in assessments, including the attached rent reasonableness form, prior to final approval. Anticipated Completion Date: Staff re-training: Completed by September 30, 2025 Integration of rent reasonableness into move-in assessment in Salesforce: October 2025 Secondary review and monitoring: Ongoing, beginning immediately Expected Outcome: These actions will ensure that all future rent reasonableness forms are completed, attached to the move-in assessment, and reviewed prior to approval of move-in. This will bring Wellspring into full compliance with both internal policy and audit requirements.

View Audit 369536

Finding 1157228 (2024-002)

Material Weakness 2024

Cirbn, LLC

IL

Procurement, Suspension & Debarment Material Weakness

Suspension and Debarment Recommendation: We recommend that for all federal funded grants CIRBN perform the required suspension and debarment verification, including implementing the necessary policies and internal controls over this process. Explanation of disagreement with audit finding: There is n...

Suspension and Debarment Recommendation: We recommend that for all federal funded grants CIRBN perform the required suspension and debarment verification, including implementing the necessary policies and internal controls over this process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will implement the necessary controls to ensure we perform the required suspension and debarment verification in the future. Name(s) of the contact person(s) responsible for corrective action: Mark DeKeersgieter Planned completion date for corrective action plan: September 2025

View Audit 369530

Finding 1157227 (2024-004)

Material Weakness 2024

Community Housing Solutions

OH

Subrecipient Monitoring Cash Management Significant Deficiency

Management will implement a dual-review process for payroll submissions, requiring both supervisor approval of timecards and accounting verification against payroll system reports. Supervisors and payroll staff will undergo training on compliance requirements. Ongoing random spot checks will be perf...

Management will implement a dual-review process for payroll submissions, requiring both supervisor approval of timecards and accounting verification against payroll system reports. Supervisors and payroll staff will undergo training on compliance requirements. Ongoing random spot checks will be performed to ensure consistency and accuracy, and to confirm compliance.

View Audit 369522

Finding 1157225 (2024-003)

Material Weakness 2024

Community Housing Solutions

OH

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

Management will enforce a standardized reimbursement packet review checklist, requiring documented approval prior to submission. All reimbursement packets will be stored electronically in a central repository. Training will be provided to all accounting staff on documentation standards. Periodic sup...

Management will enforce a standardized reimbursement packet review checklist, requiring documented approval prior to submission. All reimbursement packets will be stored electronically in a central repository. Training will be provided to all accounting staff on documentation standards. Periodic supervisory reviews will be performed to confirm compliance.

View Audit 369522

Finding 1157223 (2024-001)

Material Weakness 2024

New Beginnings

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

Finding Reference Number: 2024-001 – Internal Control over Special Tests and Provisions Description of Finding: Documentation of the rent reasonableness determination could not be located for one program participant. Statement of Concurrence or Nonconcurrence: There is no disagreement with this find...

Finding Reference Number: 2024-001 – Internal Control over Special Tests and Provisions Description of Finding: Documentation of the rent reasonableness determination could not be located for one program participant. Statement of Concurrence or Nonconcurrence: There is no disagreement with this finding. Corrective Action: Going forward, management will incorporate rent reasonableness determination procedures into the purchase request form checklist for all payments for rent assistance. Projected Completion Date: December 31, 2025

View Audit 369520 Questioned Costs: $1

Finding 1157222 (2024-001)

Material Weakness 2024

Ogden Housing INC

CT

Questioned Costs HUD Housing Programs

Action Taken: The Project is waiting for HUD’s approval on the waiver. If the waiver is denied the sponsor will return the distributed funds in excess of the amount allowed by the GPR grant terms and deposit them into a Residual Receipts account. If the waiver is approved the sponsor will be allowed...

Action Taken: The Project is waiting for HUD’s approval on the waiver. If the waiver is denied the sponsor will return the distributed funds in excess of the amount allowed by the GPR grant terms and deposit them into a Residual Receipts account. If the waiver is approved the sponsor will be allowed to retain the distributed funds.

View Audit 369518 Questioned Costs: $1

Corrective Action Plans

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