Corrective Action Plans

Finding 1230000 (2025-002)

Material Weakness 2025

Papa Ola Lokahi

HI

Subrecipient Monitoring § 200.331 § 200.332

Material Weakness Finding No. 2025-002: Subrecipient Monitoring Views of Responsible Officials and Planned Corrective Action The Organization acknowledges 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, and its subrecipient monitoring and management provisions emphasizing accountability a...

Material Weakness Finding No. 2025-002: Subrecipient Monitoring Views of Responsible Officials and Planned Corrective Action The Organization acknowledges 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, and its subrecipient monitoring and management provisions emphasizing accountability and compliance in managing federal funds and subrecipients. The Organization concurs with the prior year (2024-002) and current year renumbered recommendation (2025-002) and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). Performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. Updated, by December 31, 2024, the implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the implementation of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date. Finding No. 2025-002: Subrecipient Monitoring Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations and Sylvia Hussey, Ed.D., Chief of Staff.

View Audit 411216

Finding 1229980 (2025-001)

Material Weakness 2025

Franklin County Government

IL

Internal Control / Segregation of Duties

Franklin County will work to document current procedures and redevelop internal control procedures as appropriate for the management of federal funds.

View Audit 411207

Finding 1229979 (2025-004)

Material Weakness 2025

Howard County Housing Commission

MD

Allowable Costs / Cost Principles HUD Housing Programs § 200.430

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Allowable Costs, Payroll Disbursements - AB Recommendation: We recommend the Commission implement procedures to ensure payroll costs charged to the Housing Voucher Cluster are properly supported, accurately allocated, and reconciled to payroll rec...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Allowable Costs, Payroll Disbursements - AB Recommendation: We recommend the Commission implement procedures to ensure payroll costs charged to the Housing Voucher Cluster are properly supported, accurately allocated, and reconciled to payroll records. Management should review and approve payroll allocations and investigate any variances to ensure compliance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. This error was caused by HCHC’s timekeeping and payroll system, ADP. The error resulted in overtime hours for certain employees being paid twice in one pay period. ADP has admitted to the error and reimbursed HCHC for the costs. In order to ensure that this type of error does not occur again, HCHC is taking a number of steps. Payroll and Overtime Reconciliation: Human Resources will print and review the overtime report for each payroll cycle and reconcile the overtime hours reflected on the report against the applicable employees’ payroll records/pay stubs. Any discrepancies identified during this review will be researched and addressed promptly. Time and Attendance System: The Commission is transitioning to a new time and attendance system that is better aligned with the Commission’s operational and payroll needs. The goal of this transition is to strengthen timekeeping controls, improve the accuracy of payroll information, and provide clearer documentation to support payroll processing and allocation. Employee Payroll Review and Reporting Procedures: The Commission is updating the Employee Handbook to provide employees with clear guidance on reviewing their pay and reporting potential payroll discrepancies. The updated guidance will outline the process employees should follow if they believe they have been overpaid, underpaid, or identify another discrepancy with their compensation. Name(s) of the contact person(s) responsible for corrective action: Ikea Smith, HR Manager and Bei Hua, CFO Planned completion date for corrective action plan: January 1, 2027.

View Audit 411205

Finding 1229977 (2025-003)

Material Weakness 2025

Howard County Housing Commission

MD

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Failed Inspections - N Recommendation: We recommend that the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of d...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Failed Inspections - N Recommendation: We recommend that the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC believes that this finding was caused by the previous inspection company failing to properly communicate the results of its inspections. The new inspection companies are required to use the Commission’s Yardi software to schedule, perform and enter results. This will enhance the speed and accuracy of inspection reporting. In addition, the inspection companies are required to provide weekly reports that will be discussed and reviewed with the voucher team. Based on the results of the inspection the voucher team will be able to send abatement letters, warning letters, and/or proposed termination letters to ensure compliance with the inspection and abatement process. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: All corrections should be reflected by December 2026.

View Audit 411205

Finding 1229975 (2025-002)

Material Weakness 2025

Howard County Housing Commission

MD

HUD Housing Programs Allowable Costs / Cost Principles Material Weakness

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Inspections - N Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that it utilizes for these inspections to ensure all inspections ...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Inspections - N Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that it utilizes for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC’s third-part inspection company was not able to meet the terms of its contract or the HCVP requirements, partly due to staff turnover. As a result, HCHC terminated the contract as of the end of June, 2026, and hired two new contractors. HCHC has a third inspection company under contract to fill in when needed. Staff is providing the new contractors with a detailed SOP to ensure a mutual understanding of all necessary inspection actions. HCHC staff will meet with the inspection companies weekly to discuss progress, results and issues that arise during inspections. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: in progress all correction should be reflected by December 2026.

View Audit 411205

Finding 1229973 (2025-001)

Material Weakness 2025

Howard County Housing Commission

MD

Eligibility HUD Housing Programs Significant Deficiency

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility - E Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure that accurate data is used as part of the rent and HAP calculation. Explanation of disagreement with audit find...

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility - E Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure that accurate data is used as part of the rent and HAP calculation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC staff attended a NAHRO training that provided an in-depth review of programmatic changes. In the training the HUD hierarchy of collecting documents was reviewed while also referencing the Commission’s Administrative Plan. The voucher team meets at least monthly to discuss HCVP issues, tools, and solutions that both meet the needs of the participants and comply with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: September 2026.

View Audit 411205

Finding 1229923 (2025-004)

Material Weakness 2025

Monadnock Family Services

NH

Reporting Significant Deficiency

Corrective Action Plan: Finding 2025 – 004 corrective action is addressed in the corrective action plan for Finding 2025 – 003 as the questioned costs in 2025 – 004 relate to that finding. Management has transitioned reporting and compliance responsibilities to the Grant Manager and implemented over...

Corrective Action Plan: Finding 2025 – 004 corrective action is addressed in the corrective action plan for Finding 2025 – 003 as the questioned costs in 2025 – 004 relate to that finding. Management has transitioned reporting and compliance responsibilities to the Grant Manager and implemented oversight procedures performed by the Chief Operating Officer to ensure required reporting is completed accurately and submitted timely. Responsible Party: Michael Galea, Grant Manager Karen Johnson, Chief Operating Officer Melinda Asbury, Chief Executive Officer

View Audit 411166

Finding 1229922 (2025-001)

Material Weakness 2025

Northern Oswego County Health Services, Inc. Dba Connextcare

NY

Special Tests & Provisions Subrecipient Monitoring Eligibility

Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Action Taken Upon review, it was determined that the configuration of the Sliding Fee Discount Program within our Practice Management System had been set up ...

Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Action Taken Upon review, it was determined that the configuration of the Sliding Fee Discount Program within our Practice Management System had been set up incorrectly. Specifically, the "Slide After Insurance Method" setting was configured as CHGAMT rather than BALANCE. The Sliding Fee Maintenance settings were corrected in the system on May 27, 2026, to ensure the Sliding Fee Discount Program is applied appropriately following insurance adjudication. In addition, ConnextCare conducted a comprehensive audit of all 2026 dates of service for patients actively enrolled in the Sliding Fee Discount Program. No additional occurrences of this issue were identified. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Tracy Wimmer, CFO at (315) 264-0991. Sincerely yours, Tracy Wimmer Sr. VP/Chief Financial Officer

View Audit 411164

Finding 1229921 (2025-002)

Material Weakness 2025

Pickaway County

OH

Subrecipient Monitoring Reporting

We will correct our reporting issues with the next required report.

View Audit 411161

Finding 1229919 (2025-003)

Material Weakness 2025

TOWN OF SAINT MATTHEWS

SC

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted ...

Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted written standards of conduct governing actual, potential, and perceived conflicts of interest involving employees and governing body members who participate in the selection, award, or administration of contracts supported by federal funds. To address the finding, the Town will develop a written conflict of interest policy that complies with applicable federal requirements, including 2 CFR § 200.318(c)(1). At a minimum, the policy will: 1. Define actual, potential, and perceived conflicts of interest and prohibited conduct; 2. Identify the employees, officials, and governing body members subject to the policy; 3. Require prompt written disclosure of relevant financial interests and other potential conflicts; 4. Establish procedures for reviewing, documenting, and resolving disclosed conflicts; 5. Require affected individuals to refrain from participating in matters in which a conflict exists; 6. Establish appropriate disciplinary or corrective measures for violations; 7. Require periodic written conflict-of-interest acknowledgments and disclosures; and 8. Address the retention of acknowledgments, disclosures, determinations, and related compliance documentation. The proposed policy will be presented to the Town Council for formal consideration and adoption. Following adoption, the Town will distribute the policy to applicable employees and governing body members and provide appropriate training or written guidance regarding their responsibilities. The Town will retain completed acknowledgments, disclosures, and documentation of any conflict determinations in accordance with its applicable record-retention requirements. Management will periodically review the policy and related procedures to help ensure continued compliance with federal award requirements. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026. Current Status The Town currently does not have a written conflict of interest policy.

View Audit 411157

Finding 1229918 (2025-002)

Material Weakness 2025

TOWN OF SAINT MATTHEWS

SC

Subrecipient Monitoring Reporting

Finding 2025-002 Federal Audit Clearinghouse Reporting Finding: The single audit reporting package and data collection form were not submitted to the Federal Audit Clearinghouse within the required timeframe established by the Uniform Guidance. Corrective Action The Town will implement procedures to...

Finding 2025-002 Federal Audit Clearinghouse Reporting Finding: The single audit reporting package and data collection form were not submitted to the Federal Audit Clearinghouse within the required timeframe established by the Uniform Guidance. Corrective Action The Town will implement procedures to ensure timely completion of audits, and submission of future Single Audit reporting requirements by: 1. Assigning responsibility for monitoring federal reporting deadlines to the Town Administrator. 2. Utilizing the services of the Town's contracted CPA to assist management in monitoring audit progress and ensuring all required reports are submitted within the timeframe required by 2 CFR §200.512. 3. Providing periodic updates to Town Council regarding the status of federal compliance requirements and reporting deadlines. Responsible Official Town Administrator Anticipated Completion Date Immediately implemented and fully operational by December 31, 2026. Current Status The Town has retained a third-party Certified Public Accountant to assist with bookkeeping, compliance monitoring, and timely submission of required reports to the Federal Audit Clearinghouse.

View Audit 411157

Finding 1229917 (2025-001)

Material Weakness 2025

TOWN OF SAINT MATTHEWS

SC

Reporting

Finding 2025-001 Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding: Management does not internally prepare a complete SEFA and currently relies on significant assistance from the external auditor. Corrective Action We relied on our auditor to produce the SEFA. Our accounting d...

Finding 2025-001 Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding: Management does not internally prepare a complete SEFA and currently relies on significant assistance from the external auditor. Corrective Action We relied on our auditor to produce the SEFA. Our accounting department is small, and consists of one contracted individual, which makes it difficult. We will continue to evaluate our ability to produce our SEFA, with related footnotes when audits are required. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026, and ongoing for all future audits. Current Status The Town does not currently have personnel with the ability to prepare the SEFA.

View Audit 411157

Finding 1229916 (2025-001)

Material Weakness 2025

Reclamation District No. 108

CA

Procurement, Suspension & Debarment

We recommend that the District adopt written procurement policies and procedures that comply with the requirements of 2 CFR Part 200, including procurement methods, contract administration, and documentation. We also recommend that the District develop and implement procedures to verify and document...

We recommend that the District adopt written procurement policies and procedures that comply with the requirements of 2 CFR Part 200, including procurement methods, contract administration, and documentation. We also recommend that the District develop and implement procedures to verify and document that vendors and contractors have not been suspended or debarred prior to contract awards or making purchases.; Management's Response: The District Concurs with the finding.; Responsible Individual: Deputy Manager Meegan Nagy; Corrective Action Plan: The District will develop a written procurement policy that will include compliance with the procurement standards of the Unfiorm Guidance with the use of Federal funding.

View Audit 411155

Finding 1229904 (2025-003)

Material Weakness 2025

Special Olympics Michigan, Inc.

MI

Reporting Internal Control / Segregation of Duties § 200.512 § 200.520

Finding: In accordance with 2 CFR § 200.512(a), the audit must be completed and the reporting package, which includes the Data Collection Form (SF-SAC), must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine...

Finding: In accordance with 2 CFR § 200.512(a), the audit must be completed and the reporting package, which includes the Data Collection Form (SF-SAC), must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Recommendation: The Organization should review internal controls and implement necessary procedures to ensure that accounting processes are completed timely so the audit can be completed within the parameters of the due date. Action to be taken: management review procedures will be implemented to ensure all future submissions are completed within the deadlines required by Uniform Guidance. Responsible person - Tony Postma, Interim Chief Financial Officer.

View Audit 411115

Finding 1229902 (2025-002)

Material Weakness 2025

Journalism Development Network, Inc.

DC

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.405

Views of Responsible Officials: Management agrees with the finding. Management identified the VAT overcharge prior to the audit and requested a refund from the staffing agency. The staffing agency issued a credit of approximately $200,000 in 2026. Management identified approximately $40,000 that cou...

Views of Responsible Officials: Management agrees with the finding. Management identified the VAT overcharge prior to the audit and requested a refund from the staffing agency. The staffing agency issued a credit of approximately $200,000 in 2026. Management identified approximately $40,000 that could have been allocated back to certain affected awards. However, because some awards were closed, actual credits or adjustments program expenses and budgets were not applied. Management will enhance its review process over staffing agency invoices and vendor credits to ensure costs and related credits are reviewed for allowability, allocability, and proper award-level treatment. Name and Title of Responsible Officials: Oliver Rivers, Chief Operating Officer and Deniz Sarkinovic, Senior Director of Compliance Anticipated Completion Date: September 30, 2026

View Audit 411113

Finding 1229901 (2025-001)

Material Weakness 2025

Journalism Development Network, Inc.

DC

Subrecipient Monitoring Reporting

Views of Responsible Officials: We acknowledge this lapse. We have already updated procedures to ensure that we are registering subgrants correctly. Name and Title of Responsible Officials: Oliver Rivers, Chief Operating Officer and Deniz Sarkinovic, Senior Director of Compliance Anticipated Complet...

Views of Responsible Officials: We acknowledge this lapse. We have already updated procedures to ensure that we are registering subgrants correctly. Name and Title of Responsible Officials: Oliver Rivers, Chief Operating Officer and Deniz Sarkinovic, Senior Director of Compliance Anticipated Completion Date: September 30, 2026

View Audit 411113

Finding 1229884 (2025-003)

Material Weakness 2025

Olive View-Ucla Education & Research Institute

CA

Procurement, Suspension & Debarment § 200.214 § 200.318 § 200.327

Condition The Institute does not have a written procurement policy. Additionally, the Institute does not perform suspension and debarment verification (e.g., checking the System for Award Management (SAM.gov) or equivalent excluded parties list) prior to entering into contracts or agreements with ve...

Condition The Institute does not have a written procurement policy. Additionally, the Institute does not perform suspension and debarment verification (e.g., checking the System for Award Management (SAM.gov) or equivalent excluded parties list) prior to entering into contracts or agreements with vendors, contractors, or subrecipients. Criteria Organizations that receive federal funding are generally required, under 2 CFR § 200.318–200.327 (Uniform Guidance), to: • Maintain written procurement procedures that conform to applicable federal, state, and local laws; • Ensure procurement transactions are conducted in a manner providing full and open competition; • Verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded from participating in federal programs, per 2 CFR § 200.214 and 2 CFR Part 180. Cause The Institute has not formalized its procurement practices in a written policy and staff is not currently required to check suspension and debarment status as part of the vendor selection or contracting process. Effect Without a written procurement policy, the Institute lacks a consistent, auditable standard for procurement decisions, increasing the risk of non-compliance, favoritism, or inconsistent practices across departments. The absence of suspension and debarment checks creates risk that the Institute could enter into agreements with parties who are legally excluded from receiving federal funds, potentially resulting in disallowed costs, reputational harm, or loss of funding. Recommendation The Institute should develop and formally adopt a written procurement policy that addresses methods of procurement, competition requirements, documentation standards, and conflict-of-interest provisions consistent with 2 CFR § 200.318–200.327. The Institute should also implement a documented procedure requiring suspension and debarment verification (via SAM.gov or equivalent) for all vendors, contractors, and subrecipients prior to contract execution, and retain evidence of this check in procurement files. Management Response Management agrees with the finding and recommendation. The Institute is formalizing its procurement practices in a written procurement policy consistent with applicable Uniform Guidance requirements. The policy addresses procurement methods, competition, documentation, conflicts of interest, and suspension and debarment requirements for procurements in accordance with federal regulations. Action Taken The Institute contracted with Visual Compliance to assist with verifying vendors against all available U.S. debarred and suspended lists before entering into covered contracts or agreements with vendors, contractors, or subrecipients. The Institute has developed and approved a Suspension and Debarment policy and staff are required to check suspension and debarment status as part of the vendor selection or contracting process. The Institute is developing a written procurement policy. Evidence of the verification will be retained with the applicable procurement or agreement documentation.

View Audit 411105

Finding 1229883 (2025-002)

Material Weakness 2025

Olive View-Ucla Education & Research Institute

CA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.302 § 200.334 § 200.403 § 200.404 § 200.405

Condition During testing of cash disbursements, the audit team was unable to locate adequate supporting documentation for selected transactions sufficient to determine whether the costs charged were allowable and the activities were allowed under the applicable federal award(s). Documentation such a...

Condition During testing of cash disbursements, the audit team was unable to locate adequate supporting documentation for selected transactions sufficient to determine whether the costs charged were allowable and the activities were allowed under the applicable federal award(s). Documentation such as invoices, receipts, contracts, approvals, or evidence linking the expenditure to an allowable activity could not be located or provided by the Institute. Criteria Per 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and adequately documented. Per 2 CFR § 200.302 and § 200.334, non-federal entities must maintain financial records, including source documentation (e.g., invoices, receipts, canceled checks, time and effort records) that support the allowability, allocability, and reasonableness of costs charged to federal awards, and these records must be retained and readily accessible for a minimum of three years. Additionally, 2 CFR § 200.404 and § 200.405 require that costs be allocable and consistently applied to allowable program activities. Cause The Institute's recordkeeping and document retention practices did not ensure that supporting documentation for cash disbursements was consistently maintained, organized, or readily retrievable. This may be attributable to insufficient internal controls over document retention, lack of a centralized filing/records system, or turnover in staff responsible for maintaining disbursement records. Effect Without adequate supporting documentation, the Institute cannot demonstrate that disbursed funds were used for allowable costs and allowed activities in accordance with the terms of the federal award(s). This exposes the Institute to the risk of questioned costs, disallowed expenditures, required repayment to the funding agency, and potential findings of noncompliance in future audits. It also limits the Institute's ability to demonstrate accountability and stewardship over federal funds. Recommendation We recommend that the Institute strengthen internal controls over cash disbursements to ensure supporting documentation (invoices, receipts, approvals, and evidence of allowable activity) is obtained and retained for every transaction prior to disbursement. The Institute should implement a centralized, organized recordkeeping system (physical or electronic) for disbursement documentation, with clear responsibility assigned for maintenance and retrieval. The Institute should also provide training to relevant staff on documentation retention requirements under 2 CFR Part 200. Management’s Response Management agrees with the finding and recommendation. The Institute recognizes that complete and readily retrievable supporting documentation is necessary to demonstrate the allowability, allocability, and reasonableness of costs charged to all awards. Management will strengthen its cash disbursement and record-retention procedures to ensure invoices, receipts, approvals, contracts, and other applicable supporting documentation are maintained for each transaction. Action Taken The Institute implemented a centralized electronic recordkeeping process for cash disbursement documentation and assigned responsibility for maintaining and retrieving supporting records. Documentation supporting the expenditure and applicable approvals are retained with the transaction records. Relevant staff have been instructed on documentation and record-retention requirements applicable to federal awards. Management will hold an annual training at the beginning of the new fiscal year available to all ERI employees.

View Audit 411105

Finding 1229882 (2025-001)

Material Weakness 2025

Olive View-Ucla Education & Research Institute

CA

Reporting Special Tests & Provisions

Condition In accordance with provisions of 2 CFR Part 200 Subpart F, the filing of the data collection form and submission of audited financial statement to the Federal Audit Clearinghouse is to be completed within 9 months of the fiscal year end. The Institute did not complete the filing within 9 m...

Condition In accordance with provisions of 2 CFR Part 200 Subpart F, the filing of the data collection form and submission of audited financial statement to the Federal Audit Clearinghouse is to be completed within 9 months of the fiscal year end. The Institute did not complete the filing within 9 months of the fiscal year ended June 30, 2025. Criteria The filing of the data collection form and audited financial statement are due to the Federal Audit Clearinghouse within 9 months after the end of the audit period. Cause Due to change to new audit firm, locating supporting documents for items selected for testing and errors in the general ledger reconciliations, the audited financial statements were not completed timely. Effect The required reporting was not completed until August 2026. Recommendation The Institute should put procedures in place to ensure accurate reporting of general ledger accounts and locating supporting documents so reporting to the Federal Audit Clearinghouse can be completed within 9 months of the fiscal year end. Management’s Response Management agrees with the finding and recommendation. There has been a change in leadership at the Institute. The Institute recognizes the importance of completing the annual audit and submitting the data collection form and audited financial statements to the Federal Audit Clearinghouse within the required nine-month period. Management will move from paper-based to an electronic system in order to facilitate future audits or document requests. We will strengthen year-end close and audit preparation procedures, including monthly reconciliation of general ledger accounts, organization of supporting documentation, and coordination with the independent auditors to support timely completion of future audits. Action Taken The Institute has established an audit preparation and close schedule with assigned responsibilities and target completion dates. General ledger accounts will be reviewed and reconciled monthly and as part of the year-end close, and audit supporting documentation will be organized and maintained in a centralized location to facilitate timely retrieval. Management will monitor the audit timeline and outstanding requests to support submission to the Federal Audit Clearinghouse within the required deadline.

View Audit 411105

Finding 1229827 (2025-002)

Material Weakness 2025

Pro Bono Resource Center of Maryland, Inc.

MD

Allowable Costs / Cost Principles § 200.405

AUDIT FINDINGS Finding No. 2025-002: Allocation of Shared costs Corrective Action: Pro Bono Resource Center of Maryland (PBRC) is looking into an upgrade to its system to ensure correct allocations of all cost taking advantage of the latest Accounts Payable software. Name of Contact Person: Amy M Sm...

AUDIT FINDINGS Finding No. 2025-002: Allocation of Shared costs Corrective Action: Pro Bono Resource Center of Maryland (PBRC) is looking into an upgrade to its system to ensure correct allocations of all cost taking advantage of the latest Accounts Payable software. Name of Contact Person: Amy M Smitherman, amy.smitherman@gmail.com, 646-240-3185 Projected Completion Date: 10/15/2026 ___________________________________________________________________________________________________ Finding Reference Number: Finding No. 2025-001: Audit Adjustments Corrective Action: Pro Bono Resource Center of Maryland (PBRC) will work with our accounting firm to ensure that the appropriate steps are taken. Name of Contact Person: Amy M Smitherman, amy.smitherman@gmail.com, 646-240-3185 Projected Completion Date: 10/1/2026

View Audit 411103

Finding 1229824 (2025-002)

Material Weakness 2025

Ferndale Housing Commission

MI

HUD Housing Programs

Finding: 2025-001 and 2025-002 Federal Agency: Department of Housing and Urban Development Federal Program: Housing Choice Vouchers Audit Finding: Material Weakness Condition Identified: During the audit review of 40 participant files tested for compliance with eligibility, annual reevaluations, ten...

Finding: 2025-001 and 2025-002 Federal Agency: Department of Housing and Urban Development Federal Program: Housing Choice Vouchers Audit Finding: Material Weakness Condition Identified: During the audit review of 40 participant files tested for compliance with eligibility, annual reevaluations, tenant rent, utility allowances, and housing assistance payment requirements, the audit identified the following errors: o 15 files were not completed in a timely manner. o 1 file miscalculated the total tenant payment due to incorrect deductions applied. o 9 instances of misaligned utility responsibility across HAP Contract and Lease Agreement. Corrective Action Plan The Ferndale Housing Commission is committed to correcting all findings and ensuring accuracy in file completion, correct participant deductions, as well as correct utility responsibilities in the future. It is worth noting that the FHC was not made aware of the Zip-Code payment standards until 2026, although during a shortfall meeting held on August 25, 2025, the utility payment standards were mentioned and confirmed that they were pulled from the HUD SAFMR website, nothing regarding zip code payment standards were mentioned. Planned Corrective Actions The following actions have been implemented to ensure accuracy in reporting: All annual and interim rent certifications will be reviewed by management for accuracy prior to being accepted and submitted. o The zip code payment standards will be implemented after the HUD required mandatory one-year waiting period. The transition was explained in a letter sent to all HCV participants. o The Ferndale Housing Commission has repositioned staff to bring delinquent annual/interim reexaminations current. The restructuring was based on the strengths of the staff and has resulted in greatly reduced instances of delayed reexaminations. o All files will be reviewed for accuracy by management before submission to PIC to ensure correct uniformity and correct calculation of income, deductions, allowances, assets, payment standards, and utility responsibilities. Staff Training and Management Overview o The FHC has established mandatory weekly meetings to discuss file accuracy and ensure all staff follow the same rules, regulations, payment standards, deductions, allowances. o During the mandatory meetings, the HUD 50058 forms will be used as teaching tools and completed by hand by each staff member to ensure full understanding of the 50058 and accuracy in reporting responsibilities. o There have been monthly delayed annual recertification reports pulled and discussed with staff, with deadlines provided to bring all reports current. Strengthened Internal Controls The FHC has established checklists to be included in each file during reexamination. The checklists will list each procedure to be followed, as well as a list of mandatory documents that must be included in each file. Management will review each file prior to finalization until a noted consistency in reexamination has been reached, then periodical reviews will be implemented. Anticipated Date of Completion The corrective actions outlined have either been fully implemented or will be implemented by October 31, 2026.

View Audit 411099

Finding 1229823 (2025-001)

Material Weakness 2025

Ferndale Housing Commission

MI

HUD Housing Programs Eligibility

Finding: 2025-001 and 2025-002 Federal Agency: Department of Housing and Urban Development Federal Program: Housing Choice Vouchers Audit Finding: Material Weakness Condition Identified: During the audit review of 40 participant files tested for compliance with eligibility, annual reevaluations, ten...

Finding: 2025-001 and 2025-002 Federal Agency: Department of Housing and Urban Development Federal Program: Housing Choice Vouchers Audit Finding: Material Weakness Condition Identified: During the audit review of 40 participant files tested for compliance with eligibility, annual reevaluations, tenant rent, utility allowances, and housing assistance payment requirements, the audit identified the following errors: o 15 files were not completed in a timely manner. o 1 file miscalculated the total tenant payment due to incorrect deductions applied. o 9 instances of misaligned utility responsibility across HAP Contract and Lease Agreement. Corrective Action Plan The Ferndale Housing Commission is committed to correcting all findings and ensuring accuracy in file completion, correct participant deductions, as well as correct utility responsibilities in the future. It is worth noting that the FHC was not made aware of the Zip-Code payment standards until 2026, although during a shortfall meeting held on August 25, 2025, the utility payment standards were mentioned and confirmed that they were pulled from the HUD SAFMR website, nothing regarding zip code payment standards were mentioned. Planned Corrective Actions The following actions have been implemented to ensure accuracy in reporting: All annual and interim rent certifications will be reviewed by management for accuracy prior to being accepted and submitted. o The zip code payment standards will be implemented after the HUD required mandatory one-year waiting period. The transition was explained in a letter sent to all HCV participants. o The Ferndale Housing Commission has repositioned staff to bring delinquent annual/interim reexaminations current. The restructuring was based on the strengths of the staff and has resulted in greatly reduced instances of delayed reexaminations. o All files will be reviewed for accuracy by management before submission to PIC to ensure correct uniformity and correct calculation of income, deductions, allowances, assets, payment standards, and utility responsibilities. Staff Training and Management Overview o The FHC has established mandatory weekly meetings to discuss file accuracy and ensure all staff follow the same rules, regulations, payment standards, deductions, allowances. o During the mandatory meetings, the HUD 50058 forms will be used as teaching tools and completed by hand by each staff member to ensure full understanding of the 50058 and accuracy in reporting responsibilities. o There have been monthly delayed annual recertification reports pulled and discussed with staff, with deadlines provided to bring all reports current. Strengthened Internal Controls The FHC has established checklists to be included in each file during reexamination. The checklists will list each procedure to be followed, as well as a list of mandatory documents that must be included in each file. Management will review each file prior to finalization until a noted consistency in reexamination has been reached, then periodical reviews will be implemented. Anticipated Date of Completion The corrective actions outlined have either been fully implemented or will be implemented by October 31, 2026.

View Audit 411099

Finding 1229791 (2025-001)

Material Weakness 2025

Liberty Resources, Inc.

PA

Reporting

Name of the contact person responsible for corrective action: Glenn Seagraves, CFO Corrective Action Plan: The delay in filing was the result of significant staff turnover in Liberty Resources Inc.’s finance department producing the Organization's financial statements and the limited availability of...

Name of the contact person responsible for corrective action: Glenn Seagraves, CFO Corrective Action Plan: The delay in filing was the result of significant staff turnover in Liberty Resources Inc.’s finance department producing the Organization's financial statements and the limited availability of other resources to assist in the preparation of the financial statements. The Organization has developed and implemented a staffing plan that has adjusted the responsibilities of existing staff and has also hired new additional staff since the end of the June 30, 2024 fiscal year. Anticipated completion date: The plan has been implemented and will continue to be monitored to ensure the Organization’s ability to complete the Single Audit financial statements in a timely manner and that the data collection form can be submitted in compliance with the Single Audit requirements.

View Audit 411093

Finding 1229783 (2025-001)

Material Weakness 2025

CASA/Youth Advocates Inc.

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

Internal Control over Compliance- Subrecipient Monitoring Recommendation: We recommend all expenses incurred by subrecipients are reviewed and approved prior to reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to t...

Internal Control over Compliance- Subrecipient Monitoring Recommendation: We recommend all expenses incurred by subrecipients are reviewed and approved prior to reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to the finding: We acknowledge that prior to the completion of our January 1, 2024 December 31, 2024 audit CASA relied on summary level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. More detail regarding process in place at the time of FY2024 audit can be found in the corrective action plan for that year. Due to the timing of the FY2024 audits completion having been finalized in December 2025 procedural changes to address the concerns were not consistently implemented until the end of FY2025. As a result, the actions put in place in the prior year corrective action plan were not reflected in our FY2025 procedure. Actions taken prior to and since the issuance of the FY2024 audit include engagement of a new contracted accounting firm with a wider breadth of experience and expertise; an internal restructuring of staff to provide increased opportunity for oversight and review of contracted financial services, a new review protocol of invoices requiring verification of supporting documentation, and documentation of management approval of invoices. Also of note, the PCCD grant in question required a lengthy budget modification process, which required additional oversight and review of allowable costs. The term of this funding ends 9/30/2026 and will not be extended or renewed. Name of the contact person responsible for corrective action: Leigh Anne McKelvey, Executive Director Planned completion date for corrective action plan: 9/30/26 If the U.S. Department of the Treasury has questions regarding this plan, please call Leigh Anne McKelvey, Executive Director, at 610-565-2208.

View Audit 411088

Finding 1229779 (2025-002)

Material Weakness 2025

Center for Applied Research Solutions, Inc.

CA

Subrecipient Monitoring § 200.331 § 200.332

Management concurs with this finding, in part. As discussed in Finding 2025-001, during the period under audit, CARS had historically classified the affected entities as contractors/vendors based on management’s review and understanding of the nature of those relationships. As a result of those clas...

Management concurs with this finding, in part. As discussed in Finding 2025-001, during the period under audit, CARS had historically classified the affected entities as contractors/vendors based on management’s review and understanding of the nature of those relationships. As a result of those classifications, CARS did not apply all of the formal subrecipient monitoring requirements of 2 CFR § 200.332 to these entities. Specifically, formal subrecipient risk assessments were not performed or documented, verification of required audits under Subpart F was not incorporated into a formal monitoring process, and certain subrecipient agreements contained incorrect Assistance Listing Numbers (ALNs). CARS believes it is important to distinguish the identified deficiencies from an absence of risk evaluation, oversight or monitoring of the entities. Although CARS did not perform or document formal subrecipient risk assessments in accordance with 2 CFR § 200.332, management considered factors relevant to organizational risk during the initial proposal and partner-selection process. These considerations included CARS’ prior experience with the organizations, their demonstrated performance and funding histories, organizational capabilities, and experience administering federally funded programs, as applicable. The basis for partner selection and related considerations were reflected in the proposal documentation. During the period under audit, CARS reviewed and approved reimbursement requests for allowability and performed ongoing programmatic monitoring of performance and progress. However, because the entities were classified as contractors/vendors, these risk evaluation and monitoring activities were performed within CARS’ existing proposal, vendor, and program oversight processes rather than within a formal subrecipient monitoring framework designed to address all requirements of 2 CFR § 200.332. Based on additional training regarding subaward management under 2 CFR Part 200 and the matters identified during the current audit, management recognizes that formal written policies, documented classification determinations, and additional monitoring controls are necessary to ensure that entities determined to be subrecipients are consistently monitored in accordance with applicable Uniform Guidance requirements. CARS began corrective action and, prior to issuance of the audit report, completed the following: 1. Confirmed the correct Assistance Listing Number for the NTTAC federal award and identified subrecipient agreements requiring correction; 2. Issued modifications to affected subrecipient agreements, as necessary, to communicate the correct ALN for the applicable Year 5 modifications; 3. Reviewed available subrecipient SEFA information related to FY2025 expenditures to evaluate the accuracy of the reported ALN and communicated necessary corrections, as applicable; and 4. Obtained and reviewed available Single Audit information for the affected subrecipients and confirmed that no findings related to federal funding received from CARS were identified in the reports reviewed. Corrective Action CARS will formalize and document its existing procedures as they specifically relate to subrecipients and the applicable requirements of 2 CFR § 200.331 and § 200.332. The policy and related procedures will include documented subrecipient-versus-contractor determinations; subrecipient risk assessments; verification of required subaward information, including the Assistance Listing Number (ALN); review of financial and programmatic performance information; verification of applicable Subpart F audit requirements; review and follow-up of audit findings or other significant developments; and documentation and retention of monitoring activities, conclusions, and corrective actions, as applicable. CARS will also establish a documented pre-execution review and approval control for applicable federally funded agreements to verify the appropriate classification of the relationship and the accuracy and completeness of required federal award information before execution. As part of implementation, CARS will review applicable existing federally funded agreements under the new policy. If an existing relationship is determined to meet the criteria of a subrecipient rather than a contractor, CARS will appropriately classify the agreement, correct applicable federal award information, including the ALN, as necessary, and apply and document the required subrecipient monitoring procedures prospectively. Responsible Party: Ranelle Bensch, Director of Finance & Compliance Target Implementation Date: March 2027

View Audit 411080

Corrective Action Plans

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