Corrective Action Plans

Finding 1213591 (2025-001)

Material Weakness 2025

IL

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.317 § 200.318 § 200.32 § 200.326

Corrective Action Plans Finding 2025-001 – Noncompliant procurement policy Corrective Action Plan: The Village will update its written procurement policy to comply with applicable State, local, and tribal laws and regulations and with Federal requirements under 2 CFR §200.317–200.326. In addition, t...

Corrective Action Plans Finding 2025-001 – Noncompliant procurement policy Corrective Action Plan: The Village will update its written procurement policy to comply with applicable State, local, and tribal laws and regulations and with Federal requirements under 2 CFR §200.317–200.326. In addition, the Village will train personnel on the updated policy. This policy will apply to all purchases of goods, services, and construction funded in whole or in part by Federal awards administered by Village of Hazel Crest, including subrecipients and contractors, unless superseded by more restrictive State, local, or tribal law. Person(s) Responsible: Amanda Page-Horvet, Accounting Supervisor Timing for Implementation: Fiscal Year 2027

View Audit 400501

Finding 1213587 (2025-001)

Material Weakness 2025

R-Lcoa Housing Development Corporation, Inc.

SC

Finding 2025-001: Condition: The Corporation did not maintain a sufficient balance in the security deposit account to cover the related security deposit liabilities. Action Plan: Management concurs with the finding and is updating policies and procedures to ensure compliance in the future.

View Audit 400498

Finding 1213585 (2025-001)

Material Weakness 2025

Southwest 141 Street Housing Development Fund Company, Inc.

NY

Reporting Material Weakness

Views of responsible officials Omissions in the SEFA maintained during 2025 primarily pertain to construction lending by the City of New York’s Department of Housing Preservation and Development that utilized underlying federal funding. Management inadvertently only presented the construction lendin...

Views of responsible officials Omissions in the SEFA maintained during 2025 primarily pertain to construction lending by the City of New York’s Department of Housing Preservation and Development that utilized underlying federal funding. Management inadvertently only presented the construction lending in the years of expenditure. Such expenditures were duly reported upon and audited during the years of expenditures and were maintained within the financial records of Southwest 141 Street Housing Development Fund Company, Inc. but were subsequently omitted from the SEFA in the years following. Management concurs with Finding No. 2025-001 and, as of March 2026, management has enhanced its internal controls and augmented its personnel to ensure that such reporting under Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards is compliant, complete, and accurate for the 2025 SEFA and going forward.

View Audit 400495

Finding 1213584 (2025-002)

Material Weakness 2025

Cedar Unified School District No. 25

AZ

Reporting Significant Deficiency Internal Control / Segregation of Duties

2025-002 Single Audit Submission Planned Corrective Action Plan: The District will ensure all supporting documentation is prepared and ready for Auditors. In addition, audit services will be procured with sufficient time to submit the single audit by the required timeline. Anticipated Completion Dat...

2025-002 Single Audit Submission Planned Corrective Action Plan: The District will ensure all supporting documentation is prepared and ready for Auditors. In addition, audit services will be procured with sufficient time to submit the single audit by the required timeline. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Judy James, Business Manager

View Audit 400494

Finding 1213582 (2025-002)

Material Weakness 2025

Chelsea Jewish Nursing Home, Inc.

MA

HUD Housing Programs Cash Management

Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization was fortunate to have sufficient cash on hand in order to continue to provide the highestquality of care to its residents during the COVID-19 pandemic, primarily as a result of federal and state st...

Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization was fortunate to have sufficient cash on hand in order to continue to provide the highestquality of care to its residents during the COVID-19 pandemic, primarily as a result of federal and state stimulus funds, which were restricted in usage, received during 2020 and 2021. The Organization made it a priority to ensure that its staff continued to be compensated throughout the pandemic. Accordingly, the Organization kept cash on hand in order to meet the needs of the residents cared for daily and the dedicated staff who serve them. The Organization was not expecting a surplus cash situation at December 31, 2020 or June 30, 2021. Had the Organization not received stimulus funds through programs such as the Provider Relief Fund and Paycheck Protection Program, the Organization would not have had surplus cash at both December 31, 2020 and June 30, 2021. The required deposit due to the residual receipt account for the year ended December 31, 2020 was made on May 31, 2022. The Organization is currently in the process of discussing repayment terms for the deposit due for the period June 30, 2021 with its asset manager which includes discussions for the repayment of $1.6M in frontline costs that were funded by the Parent Organization back to the Parent. Proposed Completion Date: No later than December 31, 2026

View Audit 400478

Finding 1213581 (2025-001)

Material Weakness 2025

Chelsea Jewish Nursing Home, Inc.

MA

HUD Housing Programs

Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization is a community based non-profit and considers supporting local businesses, including a bank, a worthwhile business practice. The Organization is currently in the process of reviewing its banking re...

Name of contact person: Jennifer Santerre, Chief Financial Officer Corrective Action: The Organization is a community based non-profit and considers supporting local businesses, including a bank, a worthwhile business practice. The Organization is currently in the process of reviewing its banking relationships, and looking at other scenarios which would involve transferring funds to another institution. Proposed Completion Date: No later than December 31, 2026.

View Audit 400478

Finding 1213580 (2025-003)

Material Weakness 2025

Monterey Park Lions Club Senior Citizens Housing Corporation

CA

HUD Housing Programs Reporting

FINDING NUMBER 2025-003 Reporting views of responsible officials: The Company has already submitted the audit package into HUD’s REAC system and the Company will timely file the audit with HUD in the future. Auditors' summary of auditee's comments on the findings and recommendations: The Company has...

FINDING NUMBER 2025-003 Reporting views of responsible officials: The Company has already submitted the audit package into HUD’s REAC system and the Company will timely file the audit with HUD in the future. Auditors' summary of auditee's comments on the findings and recommendations: The Company has already submitted the audit package into HUD’s REAC System and the Company will timely file the audit package with HUD and REAC in the future. Response indicator: Agree. Response: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Completion date: October 2, 2025 Contact person: Bonnie Calvert

View Audit 400469

Finding 1213579 (2025-002)

Material Weakness 2025

Monterey Park Lions Club Senior Citizens Housing Corporation

CA

Cash Management HUD Housing Programs

FINDING NUMBER 2025-002 Reporting views of responsible officials: The Company will monitor cash balances or monitor the bank ratings. Concur or do not concur with the finding: Concur with the finding Auditors' summary of auditee's comments on the findings and recommendations: The Company should moni...

FINDING NUMBER 2025-002 Reporting views of responsible officials: The Company will monitor cash balances or monitor the bank ratings. Concur or do not concur with the finding: Concur with the finding Auditors' summary of auditee's comments on the findings and recommendations: The Company should monitor the investments held by these financial institutions to ensure that HUD’s requirements are met. Response indicator: Agree. Response: The Company should monitor the investments held by these financial institutions to ensure that HUD’s requirements are met. Completion date: December 31, 2026 Contact person: Bonnie Calvert

View Audit 400469

Finding 1213578 (2025-001)

Material Weakness 2025

Monterey Park Lions Club Senior Citizens Housing Corporation

CA

HUD Housing Programs

FINDING NUMBER 2025-001 Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on t...

FINDING NUMBER 2025-001 Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on the findings and recommendations: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Response indicator: Agree. Response: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Completion date: March 6, 2026 Contact person: Bonnie Calvert

View Audit 400469

Finding 1213508 (2025-003)

Material Weakness 2025

Seattle Indian Health Board

WA

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Planned Corrective Action: Seattle Indian Health Board will implement the following actions to ensure accurate application and documentation of the Sliding Fee Discount Program: - EPIC System Upda...

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Planned Corrective Action: Seattle Indian Health Board will implement the following actions to ensure accurate application and documentation of the Sliding Fee Discount Program: - EPIC System Update: Configure EPIC to automatically assign the appropriate sliding fee discount level to patients with zero income to ensure consistent application of the discount schedule. - Required Income Documentation at Intake: Update procedures to require front desk staff to record a patient’s income level at intake for all patients, including a reasonable estimate when documentation in unavailable. This is required for both an accurate sliding fee application and UDS reporting. - Standardized Documentation Requirements: Require retention of supporting documentation for income and family size in the patient record, or documented attestation when estimates are used, in accordance with policy. - Front Desk Training and Accountability: Provide targeted training to front desk and registration staff on sliding fee discount program requirements, with emphasis on proper data entry, documentation standards, and discount application. - Ongoing Monitoring: Implement monthly reviews of a sample of patient accounts to confirm sliding fee discounts are supported, accurately applied, and properly documented. Errors will be corrected and addressed with the staff as needed. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.

View Audit 400452

Finding 1213504 (2025-002)

Material Weakness 2025

Seattle Indian Health Board

WA

Procurement, Suspension & Debarment § 200.213

Finding 2025-002 – Suspension & Debarment (Significant Deficiency in Internal Control Over Compliance) Planned Corrective Action: Following the prior year’s audit, Finance completed a full review of all vendors exceeding the threshold in 2024 and obtained the required documentation. The vendor ident...

Finding 2025-002 – Suspension & Debarment (Significant Deficiency in Internal Control Over Compliance) Planned Corrective Action: Following the prior year’s audit, Finance completed a full review of all vendors exceeding the threshold in 2024 and obtained the required documentation. The vendor identified in 2025 was not included in that review because it did not exceed the threshold in 2024. The actions above are designed to ensure vendors are captured based on current-year activity. Seattle Indian Health Board will implement the following specific actions to ensure compliance with Uniform Guidance requirements: - Require a documented SAM.gov suspension and debarment check for all vendors prior to contract execution and once cumulative spending limits exceeds $25,000, regardless of prior year activity. - Require completion and retention of either a competitive bid summary or a written sole source justification for all covered transactions. - Perform a quarterly review of vendors with spend over $25,000 to confirm documentation is complete. Name of Responsible Party: Brian Jonas, Controller Anticipated Completion Date: September 30, 2026

View Audit 400452

Finding 1213503 (2025-001)

Material Weakness 2025

Seattle Indian Health Board

WA

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requiremen...

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requirements, specifically related to documentation of Tribal enrollment. While prior corrective actions established foundational training and audit processes, management has identified the need for stronger front-end controls, clearer accountability, and system-based safeguards to prevent recurrence. Seattle Indian Health Board will implement the following actions: 1. Strengthen Front-End Eligibility Controls - Eligibility verification protocols will be updated to require complete Tribal enrollment documentation prior to scheduling non-urgent appointments. - A standardized eligibility checklist will be embedded into intake workflows to ensure all required documentation is identified and collected before services are rendered. 2. System Enhancement and Documentation Tracking - Electronic health record workflows will be enhanced to include required fields and alters for missing eligibility documentation, including Tribal enrollment. - Patients with incomplete eligibility records will be flagged, and services will be limited to allowable scenarios until documentation is obtained. 3. Targeted Training and Competency Validation - All registration and front desk staff will undergo mandatory retraining focused specifically on Tribal enrollment documentation requirements and compliance standards. - Staff competency will be validated through post-training assessments and periodic spot checks. 4. Enhanced Monitoring and Internal Audit - Monthly eligibility audits will be expanded to include a statistically valid sample size and documented review of Tribal enrollment verification. - Audit results will be formally reported to executive leadership, with identified deficiencies tracked through resolution. - Repeat errors or noncompliance will be addressed through corrective coaching and performance management, as appropriate. Management believes these enhanced corrective actions directly address the root cause of the finding by strengthening preventive controls, improving staff competency, and increasing oversight and accountability. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.

View Audit 400452

Finding 1213496 (2025-002)

Material Weakness 2025

Detroit Wayne Integrated Health Network

MI

Allowable Costs / Cost Principles § 200.303 § 200.414

Finding Number: 2025-002 Condition: DWIHN’s internal controls were not sufficiently designed and/or operating effectively to prevent the submission of unallowable costs for reimbursement under the federal award. Planned Corrective Action: Program and finance staff responsible for the approving and p...

Finding Number: 2025-002 Condition: DWIHN’s internal controls were not sufficiently designed and/or operating effectively to prevent the submission of unallowable costs for reimbursement under the federal award. Planned Corrective Action: Program and finance staff responsible for the approving and processing of FSR’s have been informed of the need to review FSR’s in greater detail before they are submitted, approved, and payment occurs. A more detailed review of the FSR’s and adherence to established policies and procedures will eliminate the risk of errors and omissions. Contact person responsible for corrective action: Vice President of Finance and Director of Grants and Community Engagement Anticipated Completion Date: August 7, 2025

View Audit 400448

Finding 1213495 (2025-001)

Material Weakness 2025

Family Services of Westchester, Inc.

NY

Reporting

Family Services of Westchester, Inc. Corrective Action Plan For the Year Ended June 30, 2025 U. S. Department of Health and Human Services Financial Statement Finding Finding 2025-001 – Account Analyses – Material weakness Description of Finding: There were several accounts that were not properly re...

Family Services of Westchester, Inc. Corrective Action Plan For the Year Ended June 30, 2025 U. S. Department of Health and Human Services Financial Statement Finding Finding 2025-001 – Account Analyses – Material weakness Description of Finding: There were several accounts that were not properly reconciled until after year-end, resulting in material adjustments made to the general ledger. These accounts included program services revenues and receivables, grants and contracts revenues and receivables, accounts payable and due to related party. Statement of Concurrence: We concur with the finding above. Corrective Action: To strengthen the accuracy and completeness of financial reporting, the organization will implement enhanced month end procedures that include: • Preparing roll forward schedules for program service revenues, grant revenues, and related receivables to ensure beginning and ending balances are fully reconciled. • Maintaining a due to related party reconciliation schedule as part of monthly close activities. • Preparing a detailed accounts payable invoice listing reconciling to the general ledger balance. These procedures will ensure all key accounts are monitored, reconciled timely, and accurately reflected in the financial statements. Completion Date: These corrective actions were put into effect with the January 2026 month-end close. Name of Contact Person: Maria Mazzotta, CPA Chief Financial Officer Tel. No.: (914) 502-1470 E-mail: mmazzotta@odfmc.org If there are any questions regarding this Corrective Action Plan, please call Maria Mazzotta at (914) 502-1470. Sincerely yours, _________________________ Maria Mazzotta, CPA Chief Financial Officer

View Audit 400443

Finding 1213494 (2025-001)

Material Weakness 2025

The Maples Housing Corporation

MO

HUD Housing Programs Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2025 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2025 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2025. Finding 2025-001 Responsible Party: Name: Rodney Potter Position: Assistant Executive Director Telephone Number: (816) 364-3827 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comments on Finding The Maples Housing Corporation agrees with the auditors’ finding and recommendation. Corrective Action(s) We will ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. Anticipated Completion Date July 31, 2026

View Audit 400436

Finding 1213493 (2025-001)

Material Weakness 2025

Keystone Place Housing Corporation

MO

HUD Housing Programs Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2025 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2025 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2025. Finding 2025-001 Responsible Party: Name: Rodney Potter Position: Assistant Executive Director Telephone Number: (816) 364-3827 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comments on Finding Keystone Place agrees with the auditors’ finding and recommendation. Corrective Action(s) We will ensure tenants requesting maintenance of property via work orders are being maintained properly and in a timely manner and we will review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. Anticipated Completion Date July 31, 2026

View Audit 400435

Finding 1213492 (2025-018)

Material Weakness 2025

The Howard University

DC

Cash Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.305

FINDING 2025-018 Name of Responsible Individual: Director of Post Award Compliance and Training Budget Analyst Corrective Action: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In...

FINDING 2025-018 Name of Responsible Individual: Director of Post Award Compliance and Training Budget Analyst Corrective Action: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In response to the auditor’s recommendation to strengthen internal controls, Howard University will implement procedures to document and reconcile all cash payments received from sponsors on a quarterly basis to actual expenses incurred. This reconciliation process will help ensure that sponsor payments are fully accounted for and appropriately matched to related expenditures, thereby enabling the University to clearly demonstrate which expenses have been reconciled to payments received. Anticipated Completion Date: June 30, 2026

View Audit 400430

Finding 1213490 (2025-017)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

FINDING 2025-017 Name of Responsible Individual: Director of Post Award Compliance and Training Senior Associate Vice President of Financial Strategy Corrective Action: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report...

FINDING 2025-017 Name of Responsible Individual: Director of Post Award Compliance and Training Senior Associate Vice President of Financial Strategy Corrective Action: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report to the Federal Audit Clearinghouse, Howard University will enhance cross collaboration across the University to improve audit readiness. During the May 2025 transition from the Grants and Contracts Accounting Office to the Sponsored Awards Office, the University experienced significant staff turnover and a loss of institutional knowledge, which contributed to audit readiness challenges. Since that time, the University has focused on stabilization efforts. The Office of Research Sponsored Programs has been restructured and is now almost fully staffed. The University will be establishing monthly check ins with key stakeholders to ensure adherence to a compliance calendar with clearly defined roles and responsibilities across core compliance areas. Additionally, the University has hired a Director of Post Award Compliance and Training to lead audit readiness efforts, strengthen internal controls, and support ongoing monitoring and compliance throughout the fiscal year. Anticipated Completion Date: March 31, 2027

View Audit 400430

Finding 1213098 (2025-016)

Material Weakness 2025

The Howard University

DC

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302

FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted ...

FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted in incorrect exchange rate calculations. The team has implemented an updated conversion process. Going forward, the Sponsored Program Office Team will review and approve the exchange rates to ensure they are reasonable, accurate, and applied consistently. Anticipated Completion Date: June 30, 2026

View Audit 400430

Finding 1213096 (2025-015)

Material Weakness 2025

The Howard University

DC

Subrecipient Monitoring Cash Management § 200.305 § 200.332

FINDING 2025-015 Name of Responsible Individual: Assistant Vice President of Procurement Director of Post Award Compliance and Training Corrective Action: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitorin...

FINDING 2025-015 Name of Responsible Individual: Assistant Vice President of Procurement Director of Post Award Compliance and Training Corrective Action: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitoring, Howard University is implementing the following: • The University is currently piloting a new Supplier Invoice Portal, launched jointly by the Sponsored Programs Office and the Office of Procurement, to improve invoicing efficiency and compliance. Under this new process, subrecipients will be required to submit invoices electronically in accordance with the terms and conditions of their subawards. The portal will support a streamlined review and approval process, with invoices routed through an automated workflow to ensure timely review and disbursement. • To support completion of the University’s annual audit verification requirements for subrecipients, oversight will occur at multiple stages throughout the subaward lifecycle. This includes reviewing audit reports at the proposal development stage, during which subrecipients are required to complete a Subrecipient Commitment Form (implemented September 2025) prior to proposal submission. • At the award stage, refreshed due diligence will be conducted, including a re-review of the subrecipient’s Single Audit and/or financial statements. Finally, the Post Award Compliance team will perform an annual review of subrecipients’ audit reports and complete audit follow up procedures as necessary. Anticipated Completion Date: August 30, 2026

View Audit 400430

Finding 1212721 (2025-014)

Material Weakness 2025

The Howard University

DC

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.430

FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include pre...

FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include previously uncertified periods that had concluded, specifically the second half of FY25 (January–June 2025) and the first half of FY26 (July–December 2025). In May 2025, the non-accounting functions of Grants and Contracts Accounting at Howard University were transitioned to the Office of Research, Sponsored Programs Office. During this organizational transition, the University prioritized the completion and accuracy of all costing allocations to ensure payroll data was complete and reliable for effort certification purposes. This period was also utilized to identify and resolve any backlog of costing allocations and award charges and stabilize the Office of Research. Addressing these items ensured that effort reflected complete and accurate payroll activity, thereby enabling Principal Investigators to appropriately review and certify their effort. The Sponsored Programs Office (SPO) now leads post-award financial oversight and collaborates with Human Resources (HR) and Finance to ensure designated personnel are identified and granted system access to enter costing allocations and labor cost transfers in Workday. In addition, in response to the auditor’s recommendation to enhance internal controls and ensure timely monitoring of effort reporting, Howard University has implemented the following corrective actions: Hired Dedicated Departmental Support – Six College Research Administrators (CRAs) and an Associate Director of CRA’s were hired to support high-volume research colleges. The CRAs ensure timely and accurate labor cost transfers, effort certification, and costing allocation entries during award setup and throughout the award lifecycle. Enhanced Effort Reporting Process – SPO will lead improvements to the effort certification process, including: • Advance communication to PIs, CRAs, and Deans outlining certification deadlines • Clear guidance on when labor cost transfers may occur outside the certification cycle • Reinforcement that all effort changes must be reflected in the effort system to ensure alignment with payroll. • Training – Targeted training will be delivered to Principal Investigators, CRAs, and other research stakeholders to support consistent application of policies and procedures. Monitoring and Oversight – Monthly and quarterly reconciliation reports will be developed to track and validate timely and accurate payroll allocations for research personnel. Anticipated Completion Date: August 30, 2026

View Audit 400430

Finding 1212339 (2025-013)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Period of Performance

FINDING 2025-013 Name of Responsible Individual: Assistant Vice President for Pre-Award Corrective Action: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgm...

FINDING 2025-013 Name of Responsible Individual: Assistant Vice President for Pre-Award Corrective Action: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgment of federal support and a disclaimer that the contents reflect the authors' responsibility and not that of the sponsoring agency. As this is a repeat finding, the University has undertaken a comprehensive, multi-pronged corrective strategy to ensure sustained compliance going forward. Responsibility for publication acknowledgment and disclaimer compliance now resides with the Sponsored Programs Office (SPO) Pre-Award, in collaboration with the University Library. Key actions completed to date include: a formal Standard Operating Procedure finalized and approved in November 2025; mandatory publication compliance training with a required 80% passing score, serving as a prerequisite for new award setup effective November 2025; a Principal Investigator (PI) Acceptance Memo requiring signature within five business days of each award kickoff meeting to reinforce PI awareness of publication responsibilities; quarterly compliance communications issued to all federally funded PIs; and a dedicated publication compliance category added to the OOR ticketing system to streamline intake and support documentation. During Award Kickoff Meetings, acknowledgment and disclaimer requirements specific to each award are reviewed directly with the PI. SPO Pre-Award and the University Library conduct ongoing reviews of federally funded publications using available bibliometric tools, with periodic spot checks. PIs who do not meet training requirements are subject to a hold on proposal submissions until compliance is verified. Anticipated Completion Date: June 30, 2026

View Audit 400430

Finding 1211964 (2025-012)

Material Weakness 2025

The Howard University

DC

Equipment & Real Property Management Internal Control / Segregation of Duties

FINDING 2025-012 Name of Responsible Individual: Assistant Vice President of Procurement Corrective Action: Since the prior audit period, the University implemented comprehensive corrective actions, including policy updates, strengthened receiving and tagging controls, enhanced supervisory review in...

FINDING 2025-012 Name of Responsible Individual: Assistant Vice President of Procurement Corrective Action: Since the prior audit period, the University implemented comprehensive corrective actions, including policy updates, strengthened receiving and tagging controls, enhanced supervisory review in WorkDay, and ongoing communications with Suppliers and internal stakeholders. Detective and corrective controls have been established through quarterly exception reporting, monthly equipment purchase audits, and completion of a University-wide physical inventory, and required follow-up to locate, tag, or correct asset records. Moreover, the corrective action plan aims to establish an integrated, sustainable control environment. With documented procedures, active monitoring, customer communications, training, and management oversight, the University expects future audit cycles to yield favorable results. Anticipated Completion Date: December 31, 2026

View Audit 400430

Finding 1211589 (2025-011)

Material Weakness 2025

The Howard University

DC

Procurement, Suspension & Debarment

FINDING 2025-011 Name of Responsible Individual: Assistant Vice President of Procurement Corrective Action: While we acknowledge that this represents a repeat finding, the Corrective Action Plan conveys a multi-year remediation strategy that focuses on policy transparency, system controls, staffing ...

FINDING 2025-011 Name of Responsible Individual: Assistant Vice President of Procurement Corrective Action: While we acknowledge that this represents a repeat finding, the Corrective Action Plan conveys a multi-year remediation strategy that focuses on policy transparency, system controls, staffing capacity, training, and accountability mechanisms. The University will continue to address the execution and adoption challenges across Accountable Units. Since the prior audit cycle, the University has strengthened preventive controls to eliminate reliance on post-transaction modifications or corrections. The Corrective Action Plan addresses policies and procedures, OPC capacity and expertise, training and outreach, monitoring, and accountability. The Corrective Action Plan is structured to reduce reliance on detective measures and facilitate preventive compliance. Consequently, the University expects future audit cycles to yield favorable results. Anticipated Completion Date: December 31, 2026

View Audit 400430

Finding 1211214 (2025-010)

Material Weakness 2025

The Howard University

DC

Student Financial Aid Reporting Internal Control / Segregation of Duties

FINDING 2025-010 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, H...

FINDING 2025-010 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Banner to using Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” during Fall 2024 there would be no configuration issues that affect compliance. It is not possible for Financial Aid to fully test the COD disbursement reporting process prior to "go live" due to the inability to send test disbursement files to COD for reporting purposes. Once Howard disbursed loans and was able to send actual disbursement files to COD, the Enrollment Management Systems Analyst worked to identify and resolve outstanding issues. Initial reporting of disbursements to COD began on August 6, 2025. When the first disbursement file was sent to COD, the EM Systems Analyst identified the file schema sending out disbursements from Workday to COD kept rejecting the entire file. The Systems Analyst worked with the University Workday consultants to resolve the rejections and was able to correct the issue on August 28th. The cause of the rejected files between Workday and COD was an underlying Workday system issue that was corrected an updated released by Workday. There were issues in Workday regarding the school code that were identified which delayed a small cohort of students’ disbursements from being reported to COD. The Howard University enrollment school code is 00144800 and NSC required a “dummy” school code to be used for enrollment reporting of Graduate and Professional students. This “dummy” code was 00144880. A small cohort of students had loans that were rejected due to Workday reporting the 00144880 school code to COD instead of the 00144800 school code. Reconciliation identified the students and once the enrollment code sent to COD was corrected in Workday, the loan was accepted. The cost of attendance variance was a result of unfamiliarity with the Workday system. After a student's aid has been originated and disbursed, Workday will not automatically send the disbursement file back out to COD, which was not an issue Howard encountered when using Ellucian Banner. In Workday, when a student’s cost of attendance changes due to cost of attendance increase or the student’s housing status must be adjusted, there is manual intervention required. Students who have a change to their cost of attendance need to have a flag checked off in the origination record. This will allow the updated cost of attendance to be reported in COD when the next disbursement file is sent to COD. The current process is when a student's cost of attendance is manually adjusted, the flag for the record to be sent to COD is checked off in the origination record. The Associate Director for Compliance has completed internal compliance reviews testing whether disbursements are being sent to COD within 14 days. Thus far, no issues have been found in these reviews. Files are transmitted to COD at least four times per week and rejected disbursements are worked to meet the 14-day disbursement reporting timeline. A compliance review has been initiated to ensure the cost of attendance reported out of Workday matches the cost of attendance in COD. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. This process is documented and staff are trained. Anticipated Completion Date: The underlying Workday system issue resulting in the COD disbursement file being rejected was internally resolved on August 28, 2024. The Fall 2024 update released by Workday in late-September/October 2024 corrected the system from the Workday side. The Systems Analyst receives an error when there is a rejected COD file, and the correction of these files is an ongoing process. Howard staff worked with the University’s Workday consultant to resolve the incorrect school code reported to COD, causing individual students’ disbursements to be rejected. This incorrect school code reported to COD was resolved for the 2025-2026 academic year by changing the configuration of disbursements to ignore any school codes other than 00144800. The Associate Director for Compliance sends a list of rejected loan disbursements to the Financial Aid Loans Team so these rejects can be worked on and resolved in 5-7 business days. The cost of attendance variance was identified in Fall 2025 and the change in the process when a student has a manual cost of attendance increase was implemented at that time as well. The compliance reviews for cost of attendance and COD reporting will take place twice per semester and any issues identified will be resolved to avoid future findings.

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