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Corrective Action Plans

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Finding 1217975 (2025-002)
Material Weakness 2025
Marillac Community Health Centers
LA
Procurement, Suspension & Debarment
Federal Program: Congressionally Delegated Spending for Construction Projects Assistance Listing No. 93.493 Recommendation: Our auditors recommend the Organization implement a process to ensure that procurement agreements with vendors related to infrastructure projects include the Buy America domest...
Federal Program: Congressionally Delegated Spending for Construction Projects Assistance Listing No. 93.493 Recommendation: Our auditors recommend the Organization implement a process to ensure that procurement agreements with vendors related to infrastructure projects include the Buy America domestic preference provisions in each agreement, or a process to obtain a BABA (Build America, Buy America) waiver. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization was unable to locate documentation demonstrating that procurement agreements included the required Buy America (BABA) provisions or evidence of an approved waiver. In response, the Organization has implemented enhanced internal controls to ensure compliance going forward, including updates to the Procurement Policy to require inclusion of Buy America provisions or documented waivers in all applicable contracts, standardized contract templates with all required federal clauses, and a mandatory pre-award compliance checklist to verify inclusion of these elements. Additionally, procurement documentation is now maintained in a centralized system to ensure proper retention and accessibility, staff have been trained on these requirements, and ongoing compliance is monitored through quarterly reviews and required pre-execution approval for all federally funded contracts. These corrective actions have been implemented and are currently in effect.
View Audit 404172
Finding 1217974 (2025-001)
Material Weakness 2025
Marillac Community Health Centers
LA
Procurement, Suspension & Debarment
Federal Program: Congressionally Delegated Spending for Construction Projects Assistance Listing No. 93.493 Recommendation: Our auditors recommend the Organization implement a process to ensure that procurement and suspension and debarment documentation is retained. Explanation of disagreement with ...
Federal Program: Congressionally Delegated Spending for Construction Projects Assistance Listing No. 93.493 Recommendation: Our auditors recommend the Organization implement a process to ensure that procurement and suspension and debarment documentation is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization acknowledges that, in one instance, documentation evidencing that a suspension and debarment check was performed prior to engaging a vendor could not be located. While this appears to be an isolated occurrence, we recognize the importance of maintaining complete and auditable documentation to demonstrate compliance with 2 CFR Part 200 requirements. In response, the Organization has strengthened its internal controls to ensure that all vendors are properly screened and that such screenings are consistently documented. We have implemented the use of a compliance monitoring system (Compliatric), which maintains a centralized vendor registry and performs monthly screenings against federal exclusion and debarment databases, including SAM.gov and OIG exclusion lists. This system provides an auditable log of all screening activity. These enhanced controls were implemented effective June 9, 2025. Additionally, the Organization has completed a retrospective review of all active vendors to confirm that appropriate suspension and debarment screenings have been performed and documented. Going forward, any potential matches identified through the screening process will be escalated to the Risk and Compliance Manager and/or CFO for review and validation. If a match is confirmed, the Organization will immediately discontinue use of the vendor and terminate the relationship in accordance with federal requirements.
View Audit 404172
Finding 1217973 (2025-003)
Material Weakness 2025
City of Hawarden, Iowa
IA
Allowable Costs / Cost Principles Internal Control / Segregation of Duties Eligibility
2025-003 Material Weakness in Internal Control over Compliance - Review of Project Costs U.S. Department of Homeland Security Federal Emergency Management Agency Passed through State of Iowa Department of Homeland Security & Emergency Management Federal Assistance Listing Number (ALN): 97.036 Federa...
2025-003 Material Weakness in Internal Control over Compliance - Review of Project Costs U.S. Department of Homeland Security Federal Emergency Management Agency Passed through State of Iowa Department of Homeland Security & Emergency Management Federal Assistance Listing Number (ALN): 97.036 Federal Award Year: 2024 Compliance Requirement: Allowable costs/Cost Principles; Internal Control over Compliance Criteria - The Uniform Guidance requires the City to establish and maintain effective internal control over compliance for federal awards, including controls to reasonably ensure that costs charged to federal programs are allowable, properly supported, and comply with applicable federal requirements and the terms and conditions of the award. Condition - The City did not have adequately designed and implemented review controls over certain material project costs included in reimbursement requests submitted to FEMA. Our testing identified that key review procedures intended to verify the eligibility, accuracy, and supporting documentation of project costs were not consistently performed or evidenced for certain large-dollar transactions. Cause - The condition resulted from insufficient formalization and documentation of review procedures, as well as inadequate segregation of duties and oversight for the review of high­ dollar project costs prior to submission to FEMA. Effect - The absence of effective review controls over material project costs increases the risk that ineligible, unsupported, or incorrectly calculated costs could be included in reimbursement requests without timely detection and correction. This deficiency is considered a material weakness in internal control over compliance for the FEMA Public Assistance program. Recommendation - We recommend that the City design and implement formal, documented review procedures over material project costs included in FEMA reimbursement requests. These procedures should include defined review responsibilities, documentation of the review performed, and supervisory oversight to ensure that all high-dollar or complex transactions are reviewed for eligibility, accuracy, and adequate supporting documentation before submission. Views of Responsible Officials� Management agrees with the finding.
View Audit 404165
Finding 1217972 (2025-002)
Material Weakness 2025
City of Hawarden, Iowa
IA
Allowable Costs / Cost Principles Eligibility Questioned Costs
2025-002 - FEMA Public Assistance - Allowable Costs/Cost Principles - Questioned Cost U.S. Department of Homeland Security Federal Emergency Management Agency Passed through State of Iowa Department of Homeland Security & Emergency Management Federal Assistance Listing Number (ALN): 97.036 Federal A...
2025-002 - FEMA Public Assistance - Allowable Costs/Cost Principles - Questioned Cost U.S. Department of Homeland Security Federal Emergency Management Agency Passed through State of Iowa Department of Homeland Security & Emergency Management Federal Assistance Listing Number (ALN): 97.036 Federal Award Year: 2024 Criteria - Under FEMA Public Assistance program requirements and applicable federal cost principles, only eligible costs incurred by the applicant, and supported by appropriate documentation, may be claimed for reimbursement. Donated services are subject to specific eligibility criteria and documentation standards and, in certain circumstances, are not allowable as reimbursable project costs. Condition - During our testing of allowable costs, we noted that the City claimed reimbursement from FEMA for donated services that did not meet the eligibility requirements for reimbursement under the Public Assistance Program. Cause - The condition resulted from a miscommunication between the Public Works Director and payables processing clerks to process payment for an invoice that indicated donated services. Effect - As a result, ineligible costs were submitted to FEMA for reimbursement. Although the amount is not material to the federal program as a whole, it represents noncompliance with federal program requirements. Recommendation - We recommend that the City enhance its procedures over the review of costs included in FEMA reimbursement requests to ensure that donated services are evaluated in accordance with FEMA Public Assistance program requirements and are excluded from reimbursement claims when not eligible. The City should correspond with the Iowa Department of Homeland Security and Emergency Management and FEMA to discuss the proper resolution for the solution. Views of Responsible Officials - The City will immediately be in contact witH the governing authorities and work quickly and effectively to resolve the issue and will strive to obtain and understanding of the grant requirements and strengthen controls to ensure it is communicated well.
View Audit 404165
Finding 1217971 (2025-002)
Material Weakness 2025
Youth Shelters and Family Services, Inc.
NM
Questioned Costs Reporting § 200.512
Views Of Responsible Officials and Corrective Action Plan Response: Youth Shelters and Family Services (YSFS) acknowledges the finding regarding the untimely submission of the Data Collection Form to the Federal Audit Clearinghouse. YSFS recognizes the importance of timely federal reporting and unde...
Views Of Responsible Officials and Corrective Action Plan Response: Youth Shelters and Family Services (YSFS) acknowledges the finding regarding the untimely submission of the Data Collection Form to the Federal Audit Clearinghouse. YSFS recognizes the importance of timely federal reporting and understands that delays could impact funding, including grant compliance expectations, as well as impact overall good statnding. The organization has taken steps to improve coordination between internal leadership, external accounting partners, and auditors to ensure all future submissions are completed within required federal timelines. Corrective Action Plan: To address this finding and prevent future delays, YSFS will implement the following corrective actions: 1. Establish Audit and Reporting Timelines • TydeCo will develop a formal audit preparation and reporting calendar that includes key deadlines for reconciliations, audit fieldwork, financial statement review, and Federal Audit Clearinghouse submission requirements. This will be presented to YSFS Executive Director and YSFS Board of Directors. 2. Strengthen Coordination with External Accounting Firm • YSFS and contracted accounting firm TydeCo will conduct regular and frequent status meetings during audit preparation periods to monitor progress on reconciliations, supporting schedules, and audit deliverables. • Responsibilities related to audit preparation and submission requirements will be clearly assigned and documented. 3. Increase Oversight and Monitoring • Executive Director Heather Hoffman and the YSFS Finance Committee will receive periodic updates regarding audit progress and submission timelines to ensure accountability and timely completion. • TydeCo management will maintain documentation confirming submission of the Data Collection Form and related audit package. 4. Transition Stabilization and Process Improvement • As part of the organization’s transition to outsourced accounting services and implementation of Sage Intacct, YSFS will continue refining financial close and reconciliation procedures to support more timely year-end reporting. Finding resolved timeline: These corrective actions are already in progress and will be fully implemented prior to the next federal audit submission deadline. Designation of employee position responsible for meeting this deadline: Heather Hoffman, Executive Director, in coordination with Tonja Medbery, external accountant at TydeCo, and the YSFS Finance Committee, will oversee implementation and ongoing compliance with federal reporting requirements.
View Audit 404149
Finding 1217970 (2025-001)
Material Weakness 2025
THE RESOURCE ENVIRONMENT FOR UNDERPRIVILEGED GROUPS ENTERPRISE, INC.
CA
Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties
Management acknowledges that the audit for fiscal year ended June 30, 2025, was not completed and filed with the Federal Clearinghouse in a timely manner. We are working with the auditor to upload the audit the Federal Clearinghouse ASAP. We have taken steps that will ensure an earlier financial clo...
Management acknowledges that the audit for fiscal year ended June 30, 2025, was not completed and filed with the Federal Clearinghouse in a timely manner. We are working with the auditor to upload the audit the Federal Clearinghouse ASAP. We have taken steps that will ensure an earlier financial close, hence earlier audits and anticipated that the fiscal June 30, 2026, will be uploaded to the Federal Clearinghouse by the due date. Yvonne Watson, Director of Finance, will be responsible for the implementation of this CAP. We expect the upload and certification to be complete by close of business on June 19, 2026
View Audit 404147
Finding 1217969 (2025-006)
Material Weakness 2025
Corus International, Inc. and Affiliates
MD
Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403
2025-006 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of com...
2025-006 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of completion – September 30, 2026 Corrective Action Plan – Corus management concurs with this finding. In early 2025 Corus’ USAID funded project in Haiti was terminated and we were required to close down the project within two months. At that time, the security situation in Haiti was volatile and our Haiti employees were unable to regularly access the office and none of our US-based employees were permitted to travel to Haiti to assist with the project close out. As part of the close-out, Corus employed the services of a local courier company (none of the US-based courier companies were operating in Haiti at that time due to the security issues) to ship all physical supporting documentation to our offices in the US. Unfortunately, those documents were never received and despite several follow ups with the courier company, we were unable to locate the documents. The key learning was that we need to ensure that going forward all physical accounting related supporting documentation is digitized in a timely manner. This requirement was already a part of our document management policies and procedures. However, we were not regularly tracking compliance. It is important to note that the new Finance & Accounting solutions will enforce staff to digitally capture supporting documentation at the point of transaction entry, thereby transitioning us to a digital first organization.
View Audit 404146
Finding 1217966 (2025-002)
Material Weakness 2025
Wahupa Educational Services INC
CA
Reporting Internal Control / Segregation of Duties § 200.303 § 200.512
We will ensure that the financial records are maintained on a current basis, reconciled timel and audited going forward.
We will ensure that the financial records are maintained on a current basis, reconciled timel and audited going forward.
View Audit 404137
Finding 1217964 (2025-001)
Material Weakness 2025
Wahupa Educational Services INC
CA
We will ensure that the financial records are maintained on a current basis, reconciled timely, and that the assets and liabilities are accurately tracked and recorded
We will ensure that the financial records are maintained on a current basis, reconciled timely, and that the assets and liabilities are accurately tracked and recorded
View Audit 404137
Finding 1217954 (2025-001)
Material Weakness 2025
Latin American Community Center, Inc.
DE
Reporting HUD Housing Programs
To address this finding and prevent future occurrences, management has implemented the following corrective actions: 1. Responsibility for preparing and submitting HUD performance reports has been assigned to the Director of Development, with support from Apex Gov Solutions, an external consultant. ...
To address this finding and prevent future occurrences, management has implemented the following corrective actions: 1. Responsibility for preparing and submitting HUD performance reports has been assigned to the Director of Development, with support from Apex Gov Solutions, an external consultant. 2. Internal work assignments and deadlines have been established to ensure sufficient time for the preparation, review, and submission of all required reports before their due dates, which occur on the 30th day following the end of each reporting period (January 30 and July 30). 3. The Director of Development and Apex Gov Solutions will periodically review reporting requirements to ensure compliance with HUD reporting obligations and prevent future missed deadlines. Management believes these corrective actions will strengthen compliance procedures and ensure all future performance reports are completed and submitted in accordance with HUD requirements. Anticipated Completion Date The outstanding performance report is currently being completed and is expected to be submitted to HUD by June 10, 2026.
View Audit 404122
Finding 1217953 (2025-007)
Material Weakness 2025
Opportunities Industrialization Center, INC
NC
Reporting Internal Control / Segregation of Duties § 200.302 § 200.510
Classification Material Weakness Responsible Official Chief Financial Officer Anticipated Completion Date December 31, 2026 Management Response Management concurs with the finding. OIC will formalize federal award tracking and SEFA preparation procedures to ensure federal expenditures are complete, ...
Classification Material Weakness Responsible Official Chief Financial Officer Anticipated Completion Date December 31, 2026 Management Response Management concurs with the finding. OIC will formalize federal award tracking and SEFA preparation procedures to ensure federal expenditures are complete, accurate, and readily identifiable by program. Corrective Action Plan 1. Assign grant codes and Assistance Listing Number identifiers within the accounting system to track federal expenditures by award, funding source, and program. 2. Prepare quarterly SEFA reconciliations to the general ledger, grant records, reimbursement requests, and supporting documentation. 3. Incorporate a SEFA preparation checklist into year-end closing procedures and submit the draft SEFA to the Audit Committee before audit fieldwork. Management will monitor corrective action progress and provide periodic updates to executive leadership, the Finance Committee, Audit Committee, and Board of Directors until all findings are remediated. Management believes these actions will strengthen internal controls, improve audit readiness, and reduce the risk of future findings.
View Audit 404115
Finding 1217948 (2025-006)
Material Weakness 2025
Opportunities Industrialization Center, INC
NC
Reporting Internal Control / Segregation of Duties Questioned Costs § 200.302 § 200.303
Classification Material Weakness Responsible Official Chief Financial Officer and Chief Health Operations Officer Anticipated Completion Date March 31, 2027 Management Response Management concurs with the finding. OIC will strengthen revenue cycle controls to improve patient service revenue recognit...
Classification Material Weakness Responsible Official Chief Financial Officer and Chief Health Operations Officer Anticipated Completion Date March 31, 2027 Management Response Management concurs with the finding. OIC will strengthen revenue cycle controls to improve patient service revenue recognition, accounts receivable valuation, write-off governance, and billing system reconciliations. Corrective Action Plan 1. Transition from a flat encounter-based revenue estimate to a net realizable value methodology that incorporates contractual allowances, sliding fee discounts, implicit price concessions, and allowance for doubtful accounts. 2. Perform monthly documented reconciliations between EPIC, eClinicalWorks, Sage MIP, patient receivables, gross charges, adjustments, collections, write-offs, and general ledger balances. 3. Require documented management review and approval of accounts receivable aging, collectability analyses, write-offs impacting the general ledger, and revenue cycle dashboard reporting.
View Audit 404115
Finding 1217943 (2025-003)
Material Weakness 2025
Opportunities Industrialization Center, INC
NC
Reporting Material Weakness Significant Deficiency § 200.302 § 200.303
Classification Significant Deficiency Responsible Official Chief Financial Officer Anticipated Completion Date June 30, 2027 Management Response Management concurs with the finding. OIC experienced turnover in key finance positions, delayed year-end close activities, and documentation challenges dur...
Classification Significant Deficiency Responsible Official Chief Financial Officer Anticipated Completion Date June 30, 2027 Management Response Management concurs with the finding. OIC experienced turnover in key finance positions, delayed year-end close activities, and documentation challenges during the auditor transition; management will strengthen close, documentation, and audit readiness controls. Corrective Action Plan 1. Implement a documented monthly and year-end close process with defined deadlines, assigned responsibilities, balance sheet reconciliations, and documented supervisory review. 2. Maintain audit-ready support for material balances, including fixed assets, leases, beginning balances, federal awards, and other significant accounts in a centralized electronic repository. 3. Develop personnel and auditor transition procedures, including desk procedures, PBC checklists, training, and quarterly status reporting to the Finance Committee and Audit Committee.
View Audit 404115
Finding 1217940 (2025-002)
Material Weakness 2025
Senior Citizens Housing Development Corporation of Boston, INC
FL
HUD Housing Programs Eligibility Reporting
Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Boston, Inc., respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suit...
Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Boston, Inc., respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: January 1, 2025 through December 31, 2025 The findings from the December 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-002: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement stronger internal controls over the administration of tenant eligibility and file maintenance, inclusive of more rigorous staff training, to ensure HUD regulations are followed timely and accurately. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding this plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO
View Audit 404114
Finding 1217937 (2025-002)
Material Weakness 2025
Bossier Office of Community Services, Inc.
LA
Reporting
The Sr. Bookkeeper has been trained in the preparation and process of submitting the financial reports (prepare, submit, certify, and receive approval). The Finance Director works closely with the Sr. Bookkeeper to ensure the timely submission of an accurate Federal Financial Report.
The Sr. Bookkeeper has been trained in the preparation and process of submitting the financial reports (prepare, submit, certify, and receive approval). The Finance Director works closely with the Sr. Bookkeeper to ensure the timely submission of an accurate Federal Financial Report.
View Audit 404102
Finding 1217936 (2025-001)
Material Weakness 2025
Bossier Office of Community Services, Inc.
LA
Reporting
The Sr. Bookkeeper has been trained in the preparation and process of submitting the financial reports (prepare, submit, certify, and receive approval). The Finance Director works closely with the Sr. Bookkeeper to ensure the timely submission of an accurate Federal Financial Report.
The Sr. Bookkeeper has been trained in the preparation and process of submitting the financial reports (prepare, submit, certify, and receive approval). The Finance Director works closely with the Sr. Bookkeeper to ensure the timely submission of an accurate Federal Financial Report.
View Audit 404102
Finding 1217933 (2025-003)
Material Weakness 2025
Jane Addams Resource Corporation
IL
Procurement, Suspension & Debarment
Supplemental Nutritition Assistance Program – Assistance Listing No. 10.561, National Dislocated Workers Grants - Assistance Listing No. 17.277 Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine ...
Supplemental Nutritition Assistance Program – Assistance Listing No. 10.561, National Dislocated Workers Grants - Assistance Listing No. 17.277 Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred prior to entering transactions with contractors. This verification may be accomplished by: 1. Check the System for Award Management (SAM) Exclusions and save verification 2. Collecting a certification form, or 3. Adding a clause or condition to the covered transaction with that entity. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: JARC updated its internal New Vendor Procedure to strengthen controls over suspension and debarment verification for contractors and vendors. Effective in the current fiscal year, responsibility for completing and retaining System for Award Management (SAM.gov) exclusion verification was centralized within the Finance team rather than the requesting staff member to ensure consistent application of the control. Under the revised process, Finance is required to perform and retain documentation of the SAM.gov search for all new vendors and contractors prior to vendor setup and processing transactions. Evidence of the search is maintained within the vendor file and uploaded to the corresponding vendor profile in Ramp to support centralized record retention. In addition, management performed remediation procedures for existing bill pay vendors that did not previously have retained SAM.gov verification documentation. The Finance team completed and retained SAM.gov searches for applicable vendors and uploaded all saved documentation to the corresponding vendor profiles in Ramp. Management will continue monitoring compliance with this control as part of the vendor onboarding and review process. Name(s) of the contact person(s) responsible for corrective action: Gwendoly Love Thomas Planned completion date for corrective action plan: Procedure updates were implemented effective March 2026. Remediation procedures to obtain and retain SAM.gov verification documentation for vendors added prior to March 2026 will be completed by July 31, 2026.
View Audit 404095
Finding 1217928 (2025-003)
Material Weakness 2025
Town of Terry
MT
Subrecipient Monitoring
FINDING 2025-003: Audit report deadline Response: Clerk’s office will strive to develop a timeline that works for both the clerk and firm to complete the audit report on time.
FINDING 2025-003: Audit report deadline Response: Clerk’s office will strive to develop a timeline that works for both the clerk and firm to complete the audit report on time.
View Audit 404066
Finding 1217927 (2025-001)
Material Weakness 2025
Agency for Substance Abuse Prevention, Inc.
AL
Internal Control / Segregation of Duties Subrecipient Monitoring
Management of The Agency for Substance Abuse Prevention, Inc. hereby submits the following corrective action plan in response to the single audit findings for the fiscal year ending September 30, 2025: Finding 2025-001 – Segregation of Duties: Description of Finding: The auditor found that duties we...
Management of The Agency for Substance Abuse Prevention, Inc. hereby submits the following corrective action plan in response to the single audit findings for the fiscal year ending September 30, 2025: Finding 2025-001 – Segregation of Duties: Description of Finding: The auditor found that duties were not segregated in a number of areas where small adjustments to the policies of the Entity could help to further facilitate this important control. Statement of Concurrence or Nonconcurrence: Management concurs with this finding. Corrective Action: Management has issued written policies and required training of all employees that handle financial transactions and will continually evaluate processes to find ways to segregate duties where possible. Management and the board of directors will continue to oversee operations closely requiring approvals for all transactions.
View Audit 404065
Finding 1217925 (2025-001)
Material Weakness 2025
Pro Viviendas Iv, Inc.
PR
HUD Housing Programs
CORRECTIVE ACTION PLAN April 10, 2026 U.S. Department of Housing and Urban Development (HUD) Proviviendas IV, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. The findings from December 31, 2025, schedule of findings and questioned costs are discus...
CORRECTIVE ACTION PLAN April 10, 2026 U.S. Department of Housing and Urban Development (HUD) Proviviendas IV, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. The findings from December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding No. 2025-001: RESERVE FOR REPLACEMENT FUNDS Contact Person: Carmen G. Rivera Proposed Completion Date: April 30, 2026 Corrective Action: Management has been consulting with HUD’s account executive regarding the use of the reserves as collateral for financing since April 21, 2025, in a recent telephone conversation, HUD indicated that an oWicial response will be prepared and submitted in a formal letter during April 2026. Evidence of resolution will be sent to HUD. The responsible person for the corrective action plan is Carmen G. Rivera, Blanco’s Vice-President. The estimated completion date for the finding is April 30, 2026. If U.S. Department of Housing and Urban Development (HUD) has questions regarding this plan, pleases call Mrs. Carmen G. Rivera (787) 759-8018. Sincerely yours,
View Audit 404059
Finding 1217923 (2025-001)
Material Weakness 2025
Fisk University
TN
Internal Control / Segregation of Duties Questioned Costs Procurement, Suspension & Debarment
2025-001: Internal Controls Over Disbursement Approvals Action Taken/Planned: The University acknowledges the control deficiencies identified related to disbursement approval documentation for federal awards. While policies requiring multi-level approvals are formally established, management recogni...
2025-001: Internal Controls Over Disbursement Approvals Action Taken/Planned: The University acknowledges the control deficiencies identified related to disbursement approval documentation for federal awards. While policies requiring multi-level approvals are formally established, management recognizes that consistent execution and documentation of these controls were not fully adhered to in all instances. Management will formally re-communicate federal disbursement approval requirements to all relevant personnel, i ncluding principal investigators, department heads, and finance staff. This will include mandatory training sessions on federal compliance and approval protocols and distribution of updated written procedures outlining required approval l evels and documentation standards. To reduce reliance on manual processes, the University will configure the financial system/workilow to require multiple l evels of electronic approval prior to payment processing and restrict disbursement processing until all required a pprovals are completed and documented within the system. Management will implement ongoing monitoring procedures to ensure compliance, including monthly reviews of a sample of federal disbursements by the Controller's Office or Grants Accounting, quarterly compliance reporting to the CFO and senior leadership, and documentation of review results and corrective follow-up actions. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026
View Audit 404057
Finding 1217920 (2025-002)
Material Weakness 2025
Fisk University
TN
Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring
2025-002: Missing Supporting Documentation Action Taken/Planned: Management acknowledges the instance identified in which supporting documentation for a federal award disbursement could not be located at the time of audit. While this appears to be an isolated occurrence, the University recognizes th...
2025-002: Missing Supporting Documentation Action Taken/Planned: Management acknowledges the instance identified in which supporting documentation for a federal award disbursement could not be located at the time of audit. While this appears to be an isolated occurrence, the University recognizes the importance of maintaining complete and readily accessible documentation to support all federal expenditures in accordance with institutional policy and federal compliance requirements. The University will reinforce documentation and record retention requirements with all relevant personnel, including finance staff, grant administrators, and principal investigators. Additionally, management will implement enhanced controls to ensure that all required supporting documentation is properly maintained and centrally accessible. This will include transitioning toward a more standardized and, where feasible, electronic document management process to reduce the risk of missing records. Furthermore, periodic monitoring procedures will be established, including routine reviews of disbursement files to confirm the presence of required supporting documentation. Any identified deficiencies will be promptly addressed, and corrective actions will be taken to prevent recurrence. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026
View Audit 404057
Finding 1217919 (2025-003)
Material Weakness 2025
Fisk University
TN
Cash Management Period of Performance Subrecipient Monitoring
2025-003: Period of Performance Compliance Action Taken/Planned: Management acknowledges the instances identified in which disbursements were processed after the award's period of performance. While no questioned costs were noted, the University recognizes that timely processing of expenditures and ...
2025-003: Period of Performance Compliance Action Taken/Planned: Management acknowledges the instances identified in which disbursements were processed after the award's period of performance. While no questioned costs were noted, the University recognizes that timely processing of expenditures and drawdowns is critical to ensuring compliance with federal requirements governing grant periods. To Strengthening Grant Closeout Procedures management will establish a formal grant closeout timeline to begin 90 days prior to the award end date, require principal investigators (PIs) and grant administrators to review all outstanding obligations and ensure timely submission of final expenses and implement a standardized closeout checklist to confirm all costs are recorded within the allowable period To Enhanced Monitoring of Grant Periods management will develop and maintain a centralized tracking system for all federal awards, including start and end dates, generate monthly reports identifying grants nearing expiration (within 90, 60, and 30 days) and distribute reports to Pis, Grants Accounting, and Finance leadership for proactive management. For timely processing and drawdown controls management will require all invoices and expenditures to be submitted within a defined timeframe (e.g., within 30 days of service or project completion), establish internal deadlines for processing disbursements and drawdowns prior to the grant end date and implement a review step within Grants Accounting to verify that expenses fall within the period of performance before payment is released. The grants department will conduct mandatory training for PIs, grant managers, and finance staff on period of performance requirements and federal compliance expectations and reinforce accountability for timely submission and processing of expenditures Management will also put in place for any costs identified outside the period of performance will require, documented justification, review and approval by the Director of Grants Accounting and CFO, and verification of allowability under award terms or sponsor approval, if applicable. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026
View Audit 404057
Finding 1217916 (2025-003)
Material Weakness 2025
Lewis Cass Schools
IN
Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.214 § 200.303 § 200.317 § 200.318
FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Findin...
FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Finding Subject: Special Education Cluster - Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Jackquan Gray, Business Manager Contact Phone Number and Email Address: 574-626-2525 grayj@lewiscass.net Views of Responsible Officials: We Concur with the Finding. Description of Corrective Action Plan: o Create a clear procedure for all small purchases as it relates to procurement. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. o Implement a policy requiring verification of all vendors/contractors for "covered transactions" prior to entering into the contract or issuing payment. A "covered transaction" includes contracts for goods and services expected to equal or exceed $25,000. o The standard procedure should be to check the System for Award Management (SAM} exclusions (www.sam.gov) for all vendors involved in covered transactions funded with federal awards. o Establish proper segregation of duties within the procurement and payment processes to ensure no single person controls an entire transaction. Implement a review process to check for compliance with the new procedures before a purchase order is issued or a payment is made. Anticipated Completion Date: This new policy will take place immediately and the process will be followed when there is a need to check vendors in such circumstances.
View Audit 404046
Finding 1217914 (2025-001)
Material Weakness 2025
Generations United, Inc.
DC
Cash Management Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303
Views of Responsible Officials: Management acknowledges that a formal internal review and approval process over Federal drawdowns was not in place during the audit period, particularly for the more frequent drawdowns that moved from monthly to weekly. The change in drawdown practices, including perf...
Views of Responsible Officials: Management acknowledges that a formal internal review and approval process over Federal drawdowns was not in place during the audit period, particularly for the more frequent drawdowns that moved from monthly to weekly. The change in drawdown practices, including performing draws on a more frequent basis, was implemented in response to managing cash flow and external risks.Management notes that oversight was performed on a periodic basis, specifically each quarter end. Starting in May 2026, one financial party will calculate the Federal pull amount using actual costs and a 10% indirect rate, the Executive Director will review and sign off, and the Director of Grandfamilies & Kinship Support Network will initiate pulling funds from the Federal system.
View Audit 404036
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