Material Weakness in Internal Control over Compliance and Compliance - Allowable Costs Condition: During our testing of allowable costs, we identified IT-related expenses totaling $111,669 that were charged to the major program for services that were not performed by the vendor and for which the entity did not receive any benefit. These costs were subsequently reimbursed to Concilio by the funder. Recommendation: We recommend that management strengthen internal controls over vendor payments and grant billings to ensure that only costs for services actually rendered and properly supported are charged to federal awards. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has initiated corrective actions to strengthen internal controls over vendor payments, procurement, and grant billing processes. Upon discovery of the issue, management reviewed the affected transactions and ensured reimbursement of the questioned costs to the funding agency. Procedures have been enhanced to require appropriate documentation and supervisory approval confirming that services are properly rendered prior to payment and charging of costs against awards. In addition, management has strengthened vendor oversight and contract monitoring processes, including improved verification of invoices against contractual deliverables and supporting documentation. The Compliance functions have been enhanced to include periodic reviews of program expenditures, and additional staff training will be provided on allowable cost requirements, compliance standards, and documentation expectations to prevent recurrence of similar issues. Name of the contact person responsible for corrective action: Asif Mehmood, Chief Financial Officer asif.mehmood@elconcilio.net (215)627-3100 Planned completion date for the corrective action plan: June 30, 2026