Audit 352353

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria The Healthy Marriage Promotion and Responsible Fatherhood Grants require submission of financial reporting (SF-425 reports) within specified time frames. Condition During the course of our audit, we reviewed six SF-425 reports related to 93.086. Of these, we noted the Agency had submitted two annual SF-425 reports after the required due dates. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to ensure timely submission of all federal reports by the required deadlines. Additionally, we recommend management maintain documentation to show timely submission of each required report.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria The Healthy Marriage Promotion and Responsible Fatherhood Grants require submission of financial reporting (SF-425 reports) within specified time frames. Condition During the course of our audit, we reviewed six SF-425 reports related to 93.086. Of these, we noted the Agency had submitted two annual SF-425 reports after the required due dates. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to ensure timely submission of all federal reports by the required deadlines. Additionally, we recommend management maintain documentation to show timely submission of each required report.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding Yes. Refer to prior year finding 2023-001. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria The Healthy Marriage Promotion and Responsible Fatherhood Grants require submission of financial reporting (SF-425 reports) within specified time frames. Condition During the course of our audit, we reviewed six SF-425 reports related to 93.086. Of these, we noted the Agency had submitted two annual SF-425 reports after the required due dates. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to ensure timely submission of all federal reports by the required deadlines. Additionally, we recommend management maintain documentation to show timely submission of each required report.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria The Healthy Marriage Promotion and Responsible Fatherhood Grants require submission of financial reporting (SF-425 reports) within specified time frames. Condition During the course of our audit, we reviewed six SF-425 reports related to 93.086. Of these, we noted the Agency had submitted two annual SF-425 reports after the required due dates. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to ensure timely submission of all federal reports by the required deadlines. Additionally, we recommend management maintain documentation to show timely submission of each required report.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.

Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. When passing funds to subrecipients, the Agency must clearly identify to the subrecipient as a subaward, and include certain key information at the time of the subaward. These items include, but are not limited to, subrecipient name, subrecipient’s unique entity identifier, Federal Award Identification Number, Federal Award Date, Subaward Period of Performance Start and End Date, name of Federal awarding agency, and Assistance Listings number and title. Condition While performing our audit of the Agency’s subrecipient monitoring, we noted the Agency did not include all required elements in documentation to the subrecipient at the time of the subaward. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding Yes. Refer to prior year finding 2023-001. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency update their agreements with each subrecipient to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332.

Criteria Part 2 CFR Part 200, Subpart D, section 200.332 illustrates requirements related to the Agency passing funds through to subrecipients. Pass through entities must “Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved”. Condition The Agency did not have any formal controls or procedures in place for subrecipient monitoring for the STOP School Violence program or the Healthy Marriage Promotion and Responsible Fatherhood Grants until the end of the fiscal year under audit. As such, controls were not in place for the majority of the fiscal year. Cause Lack of implementation of proper policies and procedures to verify compliance with the subrecipient monitoring requirements identified in 2 CFR 200.332. Repeat Finding Yes. Refer to prior year findings 2023-003 and 2023-004. Effect The Agency did not maintain policies and procedures in accordance with the subrecipient monitoring requirements identified in 2 CFR 200.332 over the full fiscal year under audit. Noncompliance may impact future funding from federal and state resources. Recommendation We recommend the Agency implement policies and procedures to ensure compliance with subrecipient monitoring requirements, as outlined in 2 CFR 200.332. Management Response and Corrective Action Plan See attached corrective action plan.