Corrective Action Plans

Finding 1217913 (2025-004)

Material Weakness 2025

MD

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.309

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the a...

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026

View Audit 404035

Finding 1217909 (2025-003)

Material Weakness 2025

Abilities Network, Inc.

MD

Allowable Costs / Cost Principles § 200.303 § 200.407

Allowability Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend the Organization design, implement, and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Explanation ...

Allowability Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend the Organization design, implement, and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review the current internal controls over allocations and source documentation to identify any gaps or weaknesses and develop a plan to address any identified gaps or weaknesses, including updating policies and procedures as necessary. Management will also communicate the updated policies and procedures to all relevant employees and provide training as needed. Monitoring and testing procedures will be implemented to ensure that the updated policies and procedures are being followed. There will also be regular reviews and updates to the policies and procedures as needed to ensure ongoing effectiveness. Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026

View Audit 404035

Finding 1217904 (2025-001)

Material Weakness 2025

Onondaga Apartments Housing Development Fund Company, Inc.

NY

Reporting § 200.512

Finding #2025-001 Current Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Onondaga Apartments Housing Development F...

Finding #2025-001 Current Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Onondaga Apartments Housing Development Fund Company, Inc. agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact John Lutz, VP of Financial Strategy, at (315) 424-1821.

View Audit 404030

Finding 1217903 (2025-001)

Material Weakness 2025

Marion County Housing Authority

OR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

1. Implementation of Formal Written Policy MCHA implemented a comprehensive Tenant File Review Policy and Procedure in November 2025. The policy: • Establishes mandatory monthly file review requirements • Defines standardized file selection methodology • Requires consistent documentation of all revi...

1. Implementation of Formal Written Policy MCHA implemented a comprehensive Tenant File Review Policy and Procedure in November 2025. The policy: • Establishes mandatory monthly file review requirements • Defines standardized file selection methodology • Requires consistent documentation of all reviews • Assigns clear roles and responsibilities for oversight and implementation • Requires reviews to be completed monthly without exception, regardless of workload or competing priorities 2. Review Frequency and File Selection • A minimum of 14 tenant files per month are reviewed: o 7 files from the prior month (retrospective review) o 7 files from the upcoming/proactive review group • Files are selected through a randomized process within Compliance Manager, ensuring: o Representation across annual reexaminations, interim reexaminations, and new admissions o A consistent and unbiased sampling of program activity 3. Standardized Review Procedures All file reviews are conducted using a uniform, HOTMA-compliant audit checklist, requiring verification of: • Income and asset calculations • Third-party verification documentation • Required HUD forms and signatures • Accuracy of subsidy determinations (TTP, HAP, utility allowance) • Proper application of payment standards and program requirements 4. Documentation and Internal Control Measures MCHA established a centralized internal tracking system (Excel-based) to document and monitor all file reviews and corrections. • The tracking log: o Is accessible to Case Managers for visibility o Has restricted editing access limited to the Compliance Manager and HCV Program Manager • The log includes: o File selected and review date o Identified deficiencies o Date file is submitted for audit o Date file is returned for correction o Date corrections are completed and formally signed off This process ensures: • A complete audit trail of all reviews and corrections • Separation of duties • Data integrity and accountability 5. Correction and Verification Process • All identified deficiencies must be corrected within established timeframes • Corrections may include: o File documentation updates o Participant or owner follow-up • No file is closed until: o Corrections are verified o Compliance is confirmed by management o Final sign-off is documented 6. Oversight and Accountability • The Program Manager is responsible for: o Overall oversight of the policy and procedures o Ensuring monthly compliance with review requirements o Confirming all deficiencies are resolved prior to closure • The Compliance Manager is responsible for: o Execution and implementation of the review process o Conducting detailed file audits o Maintaining and controlling the tracking log o Monitoring and documenting all correction activity This structure ensures clear segregation of duties, accountability, and consistent oversight. 7. Staff Training and Acknowledgment • All Case Managers received formal training in November 2025 • Each staff member signed a written acknowledgment confirming: o Receipt of the policy o Understanding of requirements • Documentation has been: o Provided to the auditors o Retained for compliance verification Status of Corrective Action Corrective actions were fully implemented in November 2025 and are currently in effect. Planned Completion Date Completed – November 2025 Responsible Officials • HCV Program Manager – Oversight and compliance monitoring • Compliance Manager – Implementation and audit execution Conclusion MCHA believes the corrective actions implemented fully address the identified deficiency. The Authority has established formal written policies, strengthened internal controls, and implemented a structured and sustainable monitoring process. These measures ensure: • Consistent and timely tenant file reviews • Documented tracking and accountability of corrections • Ongoing compliance with HUD program requirements MCHA is confident that these controls prevent recurrence of the issues identified in this finding.

View Audit 404023

Finding 1217901 (2025-001)

Material Weakness 2025

Vineyard Village Inc.

CA

HUD Housing Programs

Department of Housing and Urban Development Vinyard Village, HUD Project No. CA39T801017, respectively submits the following corrective action plan for the audit year ended 12/31/2025. Auditor: Aprio LLP 2185 N. California Blvd, STE 350 Walnut Creek, CA 94596 SECTION I – CURRENT YEAR FINDING Finding...

Department of Housing and Urban Development Vinyard Village, HUD Project No. CA39T801017, respectively submits the following corrective action plan for the audit year ended 12/31/2025. Auditor: Aprio LLP 2185 N. California Blvd, STE 350 Walnut Creek, CA 94596 SECTION I – CURRENT YEAR FINDING Finding No.: 2025-001 Comments on Findings and Recommendations: Noted EIV report was not completed at the required 120-days interval prior to recertification date. This practice does not comply with HUD requirements. Action Taken or Planned: Clarification record added to the file. Moving Forward PS will ensure that PM runs and files away the EIV report prior to the recert effective date. Anticipated Completion Date: 11/25/2025

View Audit 404013

Finding 1217900 (2025-001)

Material Weakness 2025

Columbia Park Manor

CA

HUD Housing Programs Questioned Costs Eligibility

Department of Housing and Urban Development Columbia Park Manor, HUD Project No. CA39S931006, respectively submits the following corrective action plan for the audit year ended 12/31/2025. Auditor: Apria LLP 2185 N. California Blvd, STE 350 Walnut Creek, CA 94596 SECTION I - CURRENT YEAR FINDING Fin...

Department of Housing and Urban Development Columbia Park Manor, HUD Project No. CA39S931006, respectively submits the following corrective action plan for the audit year ended 12/31/2025. Auditor: Apria LLP 2185 N. California Blvd, STE 350 Walnut Creek, CA 94596 SECTION I - CURRENT YEAR FINDING Finding No.: 2025-001 Comments on Findings and Recommendations: Unable to locate EIV report ran within 120 days of Ml eff. 5/612025. This practice does not comply with HUD requirements. Action Taken or Planned: Clarification record added to the file. Moving Forward PS will ensure that PM runs and files away the EIV report within the HUD required timeline after Ml. Anticipated Completion Date: 11/25/2025

View Audit 404012

Finding 1217898 (2025-001)

Material Weakness 2025

Boulder Housing Partners

CO

Questioned Costs Significant Deficiency

Condition: The Authority was unable to send failed HQS inspection notices timely to participants who needed to correct deficiencies. Planned Corrective Action: Throughout 2025, BHP implemented several process improvement measures for inspections for the Housing Choice Voucher Program, including deta...

Condition: The Authority was unable to send failed HQS inspection notices timely to participants who needed to correct deficiencies. Planned Corrective Action: Throughout 2025, BHP implemented several process improvement measures for inspections for the Housing Choice Voucher Program, including detailed preparations for the implementation of NSPIRE standards. As noted in the audit, BHP needed to improve our timely notification to landlords of failed inspection items. To address the noted deficiency, BHP implemented a daily email notification to the HCV team summarizing all failed inspections that have occurred in the prior 48 hours. These improvements were implemented in the second half of 2025 and have successfully addressed the noted concern. In addition, BHP implemented additional inspection improvements during the year, including hiring additional qualified personnel to assist with scheduling inspections, as well as timely distribution of any notices of failed inspections. BHP is working to improve our processes to better serve clients and create efficiencies within their workflows as we prepare for full NSPIRE implementation. Contact person responsible for corrective action: Karen Brunnemer, MTW and Federal Policy Director and Omar Llamas, HCV Program Manager Anticipated Completion Date: 12/31/2026

View Audit 403998

Finding 1217897 (2025-003)

Material Weakness 2025

Mount Sinai Foundation, Incorporated 053-36322

NC

HUD Housing Programs

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN May 13, 202 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits t...

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN May 13, 202 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits the following Corrective Action Plan for the year ended December 31, 2025. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings for the year ended December 31, 2025 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - Financial Statement Audit and Federal Award Program Audits Finding 2025-003 - U.S. Department of Housing and Urban Development, Mortgage Insurance Rental and Cooperative Housing for Moderate Income Families and Elderly, Market Interest Rate (Sections 221d(3) and (4) Multifamily - Market Rate Housing), CFDA #14.135 Recommendation: That management ensure that the annual financial reports to HUD are submitted by the required due dates. Action Taken: We agree with Finding 2025-003 and the recommendation described in the accompanying schedule of findings and questioned costs. Management is taking steps to improve cash flow and will ensure the annual financial report to HUD for the year ended December 31, 2025, is submitted timely. Sincerely yours, Shannon Pow President Remnant Management, Inc.

View Audit 403993

Finding 1217896 (2025-002)

Material Weakness 2025

Mount Sinai Foundation, Incorporated 053-36322

NC

Questioned Costs HUD Housing Programs Reporting § 200.512

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN May 13, 2026 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits ...

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN May 13, 2026 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits the following Corrective Action Plan for the year ended December 31, 2025 Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings for the year ended December 31, 2025 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - Financial Statement Audit and Federal Award Program Audits Finding 2025-002 - U.S. Department of Housing and Urban Development, Mortgage Insurance Rental and Cooperative Housing for Moderate Income Families and Elderly, Market Interest Rate (Sections 221d(3) and (4) Multifamily - Market Rate Housing), CFDA #14.135 Recommendation: That management ensure that the data collection forms are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2025-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management is taking steps to improve cash flow and will ensure the data collection form for the year ended December 31, 2025, is submitted timely. Sincerely yours, Shannon Pow President Remnant Management, Inc.

View Audit 403993

Finding 1217895 (2025-001)

Material Weakness 2025

Mount Sinai Foundation, Incorporated 053-36322

NC

HUD Housing Programs Matching / Level of Effort / Earmarking

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN May 13, 2026 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits ...

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN May 13, 2026 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits the following Corrective Action Plan for the year ended December 31, 2025. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings for the year ended December 31, 2025 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - Financial Statement Audit and Federal Award Program Audits Finding 2025-001 - U.S. Department of Housing and Urban Development, Mortgage Insurance Rental and Cooperative Housing for Moderate Income Families and Elderly, Market Interest Rate (Sections 221d(3) and (4) Multifamily - Market Rate Housing), CFDA #14.135 Recommendation: We recommend that management review surplus cash calculations and related payment requirements under the Loan and Regulatory Agreements and implement procedures to ensure required payments are made timely when surplus cash is available. Action Taken: We agree with Finding 2025-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management responded to the fiscal year ended 2022 SEBA report on December 23, 2024. As of the date of this report, the Corporation has not received any further communication from the SEBA regarding this matter. Management will continue to review surplus cash requirements and payment obligations under the Loan and Regulatory Agreements. Additionally, management will monitor surplus cash annually and ensure required payments are made in compliance with applicable agreements. Sincerely yours, Shannon Pow President Remnant Management, Inc.

View Audit 403993

Finding 1217888 (2025-002)

Material Weakness 2025

Housing Authority of the County of Butte

CA

HUD Housing Programs

The HUD San Francisco field office will be conduction a SEMAP confirmatory on site of HACB which includes review of documents and submitting SEMAP certification on behalf of HACB. For future submissions, HACB will create a system of checks and balances that will follow the following process: 1. SEMA...

The HUD San Francisco field office will be conduction a SEMAP confirmatory on site of HACB which includes review of documents and submitting SEMAP certification on behalf of HACB. For future submissions, HACB will create a system of checks and balances that will follow the following process: 1. SEMAP will be completely by Rental Assistance Programs Manager and submitted for HACB Board Approval. 2. Immediately following approval by the HACB Board, the rental Assistance Programs Manager and the Executive Assistant will alert the Executive. 3. The deputy Executive Director will provide oversite that the certification has been submitted no later than the deadline of 11/30.

View Audit 403973

Finding 1217836 (2025-005)

Material Weakness 2025

County of Humboldt

CA

Reporting § 200.328 § 200.329

Significant Deficiency in Internal Control over Compliance, Other Matter Condition: During our testing, we noted that 3 of the 5 Airport Improvement Program grants tested for SF-425 were not submitted for Fiscal year ended June 30, 2025. Recommendation: CLA recommends that the County continue provid...

Significant Deficiency in Internal Control over Compliance, Other Matter Condition: During our testing, we noted that 3 of the 5 Airport Improvement Program grants tested for SF-425 were not submitted for Fiscal year ended June 30, 2025. Recommendation: CLA recommends that the County continue providing staff with training related to identifying and complying with grant reporting requirements. In addition, CLA recommends that the County maintain and enhance tracking procedures, such as a monitoring checklist, to ensure all required grant reports including those related to prior‑year activity are submitted accurately and in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Implement a tracking system, train support staff, continue to file past-due reports, and file ongoing reports timely. Name(s) of the contact person(s) responsible for corrective action: Aviation Director Planned completion date for corrective action plan: 6/30/2026

View Audit 403968

Finding 1217832 (2025-003)

Material Weakness 2025

Buckner International and Subsidiaries

TX

Questioned Costs Reporting Significant Deficiency

Corrective Action Plan Program Managers responsible for submitting Performance Reports must copy the appropriate Contract Administrator, Director of Contracts, Accountability & Risk Management and the Director of Transition Services on all correspondence related to report submissions. When an extens...

Corrective Action Plan Program Managers responsible for submitting Performance Reports must copy the appropriate Contract Administrator, Director of Contracts, Accountability & Risk Management and the Director of Transition Services on all correspondence related to report submissions. When an extension is needed, the Program Manager will request written approval from TWC. If an unexpected delay occurs, the Program Manager will notify TWC in writing and confirm the anticipated submission date to support compliance with reporting deadlines. Program Managers will also create tasks and calendar reminders for all applicable reporting and billing due dates. Person(s) Responsible: Bekah Coggins, Director of Transition Services Anticipated Completion Date: Effective May 4, 2026, and onward

View Audit 403954

Finding 1217831 (2025-002)

Material Weakness 2025

Buckner International and Subsidiaries

TX

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these r...

Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these reports reflect actual amounts posted to internal accounts rather than estimated expenditures, they are used to cross-reference program expenses and support billing submissions. Buckner also implemented additional levels of review to ensure the Program Manager completes billing documentation accurately, the Program Director reviews followed by final review by the Finance Administrator. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective August 20, 2025, and onward

View Audit 403954

Finding 1217830 (2025-001)

Material Weakness 2025

Buckner International and Subsidiaries

TX

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calcula...

Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calculate allocations and reduce errors. Each month, the Finance Administrator calculates allocations based on time worked, provides them to the Program Director for billing, and reviews state billing submissions to confirm accuracy. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective June 20, 2025, and onward

View Audit 403954

Finding 1217827 (2025-001)

Material Weakness 2025

City of Bloomington, Minnesota

MN

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

Corrective Action Plan Actions Planned – The HRA will implement and monitor controls to ensure policies and procedures related to tenant eligibility determinations and recertifications are consistently followed. Official Responsible – Sarah Abe, HRA Administrator Planned Completion Date – December 3...

Corrective Action Plan Actions Planned – The HRA will implement and monitor controls to ensure policies and procedures related to tenant eligibility determinations and recertifications are consistently followed. Official Responsible – Sarah Abe, HRA Administrator Planned Completion Date – December 31, 2026 Disagreement With or Explanation of Finding – The HRA agrees with this finding. Plan to Monitor – Sarah Abe, HRA Administrator, will oversee the process to ensure tenant checklists for eligibility are completed and a separate program specialist is assigned to review and sign off on the checklists.

View Audit 403946

Finding 1217826 (2025-010)

Material Weakness 2025

Englewood Board of Education

NJ

Procurement, Suspension & Debarment

Management has reviewed this finding and indicated it will review and revise its procedures to ensure corrective action is taken.

View Audit 403939

Finding 1217824 (2025-002)

Material Weakness 2025

Madison County

MT

Reporting

FINDING 2025-002: Audit report deadline Response: Finance will improve year-end reporting and closing procedures to help ensure the financial information is completed on time and future audit deadlines are met.

View Audit 403934

Finding 1217823 (2025-003)

Material Weakness 2025

Virginia Foundation for Community College Education

VA

Subrecipient Monitoring § 200.339

View of Responsible Officials The Foundation did indicate to the subrecipients that the subawards were federal funds and outlined terms and uses associated with the subawards. The Foundation also monitored and reviewed subrecipient reimbursement submissions and corresponding support to ensure reques...

View of Responsible Officials The Foundation did indicate to the subrecipients that the subawards were federal funds and outlined terms and uses associated with the subawards. The Foundation also monitored and reviewed subrecipient reimbursement submissions and corresponding support to ensure requests complied with the terms and conditions of the subaward. Action planned: • Develop and implement written policies and procedures that: o Establish a formal process for identifying all subrecipients receiving federal awards and determining which ones meet the single audit threshold. o Define procedures to ensure subrecipients complete the required audits under 2 CFR 200 Subpart F. o Outline steps for reviewing subrecipient audit reports, identifying findings related to the Foundation's subawards, and ensuring the subrecipient develops a corrective action plan for those findings. o Formalize the process for the Foundation to issue a management decision on relevant findings within the required six-month timeframe. o Include procedures for considering sanctions if a subrecipient does not comply with audit requirements. • Perform a lookback review: o Review existing subrecipient agreements to identify any instances of non-compliance with past monitoring requirements and ensure the necessary follow-up actions (e.g., obtaining audit reports, issuing management decisions) are completed for those periods. • Establish a monitoring system: o Implement a tracking system (e.g., a spreadsheet or software) to monitor the status of subrecipient audits, deadlines for management decisions, and follow-up on corrective actions. o Designate a responsible individual/department to oversee the subrecipient monitoring process and ensure all requirements are met consistently. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. The Finance Manager will be responsible for overseeing the implementation and ongoing compliance of the new subrecipient monitoring procedures. Timeline: • February 2026: Policy approved and implemented, and lookback review of prior periods completed. • Ongoing: Continuously monitor subrecipients and ensure timely action is taken on all future audit findings.

View Audit 403931

Finding 1217822 (2025-002)

Material Weakness 2025

Virginia Foundation for Community College Education

VA

Subrecipient Monitoring Questioned Costs Reporting

View of Responsible Officials In partnership with the federal program officers assigned to the three federal grant awards, the Foundation filed all required reporting available in SAM.gov by the specified due dates. Action taken: Following the government reopening, the Foundation reached out multipl...

View of Responsible Officials In partnership with the federal program officers assigned to the three federal grant awards, the Foundation filed all required reporting available in SAM.gov by the specified due dates. Action taken: Following the government reopening, the Foundation reached out multiple times to the federal program officers to clarify and determine the requirements for proper reporting in accordance with the grant agreements. The response received was that they were not familiar with the Federal Funding Accountability Transparency Act and suggested filing the report independently. Action planned: Based on the response, the Foundation will file the required reporting. Specific steps: The Foundation will work with the U.S. Department of Education to ensure the proper steps for filing the missing reports are taken and all required information is submitted. In addition, the Foundation will develop and implement a written policy to provide clear guidance on FFATA reporting responsibilities, including the criteria for identifying reportable subawards and the required submission process and deadlines alongside an internal review process. Responsibility: • The Director of Development, Chief Operating Officer, and Finance Manager will ensure the three FFATA reports are filed. • The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: • The Foundation will file required reporting alongside due dates outlined by Federal Funding Accountability Transparency Act. • Policy approved and implemented by March 2026.

View Audit 403931

Finding 1217821 (2025-001)

Material Weakness 2025

Virginia Foundation for Community College Education

VA

Questioned Costs Cash Management Internal Control / Segregation of Duties

View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to th...

View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to the minimum amounts needed and were timed with actual, immediate cash requirements to carry out the purpose of the approved programs and projects. With regards to College and Career Success for Foster Youth through Work-based Learning Opportunities and Coaching Support under ALN 84-116Z, the Foundation was notified by the U.S. Department of Education on September 12, 2024, that unused principal be returned. On September 25, 2024, the funds in the amount of $753,800 were refunded by wire transfer. This was the only notification the Foundation received from the U.S. Department of Education; no other notification was received regarding other advance payments made during the fiscal year. With regards to Improving the Quality of Early Childhood Educators under ALN 84-116Z, the Foundation did not receive any notification from the U.S. Department of Education requesting that advance payments be returned. In all instances of advance payments, the Foundation maintained funds in interest bearing accounts as outlined in the respective agreements for the three federal awards. With regards to the requests for advances that were made on a quarterly basis, the respective agreements for the three federal awards do not explicitly outline a timeframe for advance payments, nor did these advances trigger the federal government’s threshold for excessive drawdown. Estimated quarterly advance payments were made from the uncertainty of the U.S. Department of Education clawing back award funding while ensuring sufficient cash on hand to support approaching distributions to students and colleges and mitigating risk to the Foundation covering respective distributions with its own funds. Brown Edwards shared the suggested interpretation is a one-to-three-day timeframe between drawdown and distribution. Action taken: The Foundation calculated advance payment balances as of November 4, 2025, and issued respective returns to the U.S. Department of Education on November 5, 2025. Subsequent drawdowns have been made on a reimbursement basis. Action planned: The Foundation will revise its policies and procedures for requesting federal funds to ensure that requests for advance payments be limited to the minimum amounts needed and be timed with actual, immediate cash requirements to carry out the purpose of approved programs and projects. Specific steps: The Foundation will develop and implement a written policy requiring a documented review of immediate cash needs before any federal fund drawdown request is submitted and establishing a process to request funds on a reimbursement basis or just-in-time advance basis to align drawdowns with actual disbursements. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: Policy approved and implemented by February 2026.

View Audit 403931

Finding 1217763 (2025-002)

Material Weakness 2025

Green County Family Ymca, Inc.

WI

Procurement, Suspension & Debarment § 200.318

Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized pur...

Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization plans to review its procurement and suspension and debarment policies and assess necessary changes to be in accordance with Uniform Guidance going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2026

View Audit 403919

Finding 1217762 (2025-001)

Material Weakness 2025

Green County Family Ymca, Inc.

WI

Reporting Material Weakness

Assistance Listing No. 21.027 Recommendation: CLA recommends that the Organization implement procedures for verifying that performance reports are reviewed and all reports are submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ta...

Assistance Listing No. 21.027 Recommendation: CLA recommends that the Organization implement procedures for verifying that performance reports are reviewed and all reports are submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has implemented procedures subsequent to year-end to ensure that performance reports are reviewed prior to submission and that all reports are submitted timely going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2026

View Audit 403919

Finding 1217761 (2025-002)

Material Weakness 2025

Town of Brunswick Maine

ME

Reporting

Management Response/Corrective Action Plan: The Finance Office has a monthly task list to ensure reports and other required tasks are completed in a timely manner. Quarterly reports for the Apprenticeship Program grant have been added for future quarters. This practice will be followed for future gr...

Management Response/Corrective Action Plan: The Finance Office has a monthly task list to ensure reports and other required tasks are completed in a timely manner. Quarterly reports for the Apprenticeship Program grant have been added for future quarters. This practice will be followed for future grants.

View Audit 403915

Finding 1217760 (2025-001)

Material Weakness 2025

Town of Brunswick Maine

ME

Procurement, Suspension & Debarment § 200.214 § 200.317 § 200.320 § 200.327

Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of...

Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.

View Audit 403915

Corrective Action Plans

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