Corrective Action Plans

2023-045 Oregon Housing and Community Services Obtain documentation to support expenditures or pursue cost recovery MANAGEMENT RESPONSE: We agree with this recommendation. OHCS is in the process of coordinating with agencies and contractor to resolve any outstanding compliance concerns. Expenses may be considered mitigated if documentation to support the questioned cost is obtained, or if agency is able to clarify policy and procedure to support existing documentation. If expenditure is not resolved and is identified as non-compliant with federal requirements, OHCS may pursue cost recovery. Anticipated Completion Date: July 31, 2024 Contact person: Liz Weber, Chief Policy Officer

2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in time to complete action prior to end of audit work, however work will be finalized prior to the end of the current fiscal year. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

Finding 2023-067 – Corrective Action Plan EOHHS amended and updated its guidelines and standard operating procedures leveraging the CMS ‘Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming’ as a source document. In addition to ensuring alignment with CMS requirements, the updated guidelines include a uniform schedule of quarterly submission dates and details the billing responsibilities of participating LEAs. These responsibilities include meeting all Medicaid documentation requirements; submitting the Certification of Local Funds on a quarterly basis; and signing provider agreements and maintaining all other records used to support claims submitted for Medicaid reimbursement. Upon receipt of these submissions a new audit tool will be utilized to ensure each submissions contains the required documentation. EOHHS Medicaid Program Integrity will also collect the claims data, sort the list, comprise a sample, perform the review, and issue a report for participating LEAs. In the event of missing documentation, incomplete documentation, or an error, the LEA and their billing contractor will be notified. Failure to resubmit the missing file(s) or failure to address any errors identified will result in a withhold of reimbursement for that LEA until the following quarter. A finalized spreadsheet is then sent to finance for reimbursement. EOHHS is also engaged with the school-based services TA Center and will continue leverage this engagement to ensure compliance with CMS guidelines. Anticipated Completion Date: June 1, 2024 Contact Person: Tyler McFeeters, Health Program Administrator, Executive Office of Health & Human Services tyler.mcfeeters@ohhs.ri.gov

Finding 2023-063 – Corrective Action Plan Each health plan reports TPL recoveries to EOHHS in its quarterly financial report (FDCR). These recoveries are used as a direct offset to medical expenses. As such, claims paid by the plans on behalf of a member with TPL will remain in the EOHHS encounter data warehouse. Health plans do not void claims that have previously been paid to account for any TPL liability. Rather, they seek to recover from the third party any amount owed and report that amount to the state. In each of the last two fiscal years, this reduced medical expenditures by just under $8 million. EOHHS sent the MCOs a full TPL file in July 2023. EOHHS will start the process for a new file in June 2024. Anticipated Completion Date: Ongoing Contact Person: Jeffrey Schmeltz, Chief of Family Health Systems, Executive Office of Health & Human Services jeffery.schmelts@ohhs.ri.gov

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan components including any combination of education and work-related activities in the approved plan are determined by RIW Regulations, section 2.11. The need for services in an RIW CCAP case is based on the employment plan. In situations where an applicant parent does not comply with the RIW employment plan, CCAP services would not be approved. Once CCAP services are approved based on an employment plan for an RIW recipient, the approval is for a 12-month certification period and would not be terminated, per ACF federal requirements, for a subsequent change in employment plan participation or change in income (unless in excess of 85% SMI). It should be noted that in all cases, the decortications were documented in Bridges. CCAP training has also been enhanced in many ways. CCAP training is delivered along with RIW training on a bi-monthly basis for new hires and/or existing ETs The CCAP training module was revised to include topics specific to improper payments. Office of Child Care also holds monthly CCAP office hours for operations staff to connect with program admins, policy and training specialist to answer/troubleshoot questions from the field. Monthly analysis by error type now includes location and worker ID for analysis of more targeted training. DHS also continues to look at system and process improvements. Weekly CCAP theme meetings are ongoing to identify and solution Bridges related incidents. The CCAP Regulations have been reviewed and were opened Q1 2024 for policy updates to streamline and simplify verification processes where possible. Anticipated Completion Date: July 1, 2024 Contact Person: Nicole Chiello, Assistant Director – Office of Child Care, Department of Human Services nicole.chiello@dhs.ri.gov

Finding 2023-055 – Corrective Action Plan Management agrees with the finding. 2023-055a – DHS has subsequently reviewed the SOC 2 report and will submit to Accounts & Control. 2023-055b – Passwords have already been changed to meet the ETSS policy. 2023-055c – DHS will review user access every 60 days or 90, respectively and terminate users as necessary. Anticipated Completion Date: June 30, 2024 Contact Persons: Deirdre Weedon, Chief Program Development, Low Income Home Energy Assistance Program (LIHEAP), Department of Human Services deirdre.weedon@dhs.ri.gov Ben Quattrucci, Associate Director, Financial & Contract Management, Department of Human Services benjamin.a.quattrucci@dhs.ri.gov

Finding 2023-054 – Corrective Action Plan 2023-054a – The State (EOHHS) receives quarterly user access reports from the MMIS fiscal agent. Anyone identified on the reports that have not logged in for a period of 60 days will have their access deleted. Currently, they are locked out and cannot access the system without first requesting a password reset, which is reviewed and approved/denied by EOHHS systems group. In addition, when a user leaves state service or moves to another agency, their access is deleted. 2023-054b – The State (EOHHS) collaborates with system vendors (MMIS/Gainwell and Deloitte/RI Bridges) Maintenance & Operations (M&O) and Security teams and to ensure annual risk assessment/vulnerability best practices and lessons learned are integrated into annual planning and scope of work for future FYs. Anticipated Completion Date: Current and Ongoing Contact Persons: Brian Tichenor, RIBridges Medicaid Administrator, Executive Office of Health & Human Services brian.tichenor@ohhs.ri.gov Hector Rivera, Interdepartmental Project Manager, Executive Office of Health & Human Services hector.l.rivera@ohhs.ri.gov

Finding 2023-049 – Corrective Action Plan RIDOH agrees with the finding and recommendation. The unreported subawards of ELC funds were Memoranda of Understanding (MOU) agreements with Local Education Agencies and other schools in Rhode Island for the ELC COVID Reopening Schools award and were not recognized as being subject to FFATA reporting. RIDOH will review all internal policies and procedures regarding both subawards and interagency agreements with federal funds (IAA-FF), and FFATA reporting thereof, to assure RIDOH is aligned with the statewide DOA policies for FFATA reporting. RIDOH will provide training to all contract managers, program managers for subawards, and staff responsible for reporting in FSRS to assure all subawarded funds are captured and reported appropriately. Anticipated Completion Date: December 31, 2024 Contact Persons: Alisha Colella, Chief Financial Officer, Rhode Island Department of Health alisha.colella@health.ri.gov Carla Lundquist, Deputy CFO / Federal Grants Manager, Rhode Island Department of Health carla.lundquist@health.ri.gov

Finding 2023-048 – Corrective Action Plan RIDE recognizes that CTE Program Monitoring did not reflect US DOE format and therefore developed a monitoring tool that meets USDOE layout and functionality. Using district provided CTE data, RIDE will review written documentation provided by the secondary/postsecondary districts being monitored. The monitoring will consist of both a desk audit and an onsite inspection of the subrecipients. After the review process is complete a report for subrecipients will be sent back to the subrecipients that were monitored. This may include next steps and the need (if any) for corrective action. Anticipated Completion Date: On May 1, 2024, and May 3, 2024, RIDE will begin monitoring a secondary and postsecondary Perkins recipient. RIDE will continue with subrecipient monitoring visits in each subsequent fiscal year to satisfy the requirements of the USDOE. Contact Person: Paul McConnell, Career & Technical Education Data Specialist, Department of Elementary & Secondary Education paul.mcconnell@ride.ri.gov

Finding 2023-044 – Corrective Action Plan 2023-044a – RIDE has developed written policies and procedures for the maintenance of AcceleGrants user accounts that will have all inactive users removed after 12 months of inactivity. Anticipated Completion Date: October 31, 2024 2023-044b – RIDE finance and IT offices will review the user complementary controls noted in the vendors most currently available SOC2 report and implement suggested controls that are deemed appropriate, reasonable, and necessary by the joint RIDE team. RIDE will have this finding resolved by December 31,2024. Anticipated Completion Date: December 31, 2024 2023-044c – Finance and IT at RIDE are working together to determine the correct schedule for regular IT risk assessments. The departments are also in the process of reviewing the disaster recovery plans for the vendor, and a vendor management plan. Anticipated Completion Date: December 31, 2024 Contact Person: Mark Dunham, Chief Financial Officer, Department of Elementary & Secondary Education mark.dunham@ride.ri.gov

Finding 2023-043 – Corrective Action Plan Parameters regarding charter management organizations are in the charter school application, but additionally, Charter Management Organizations applicants will be asked to file a plan with the Office of School Opportunities on how they will avoid conflicts of interest and related party transactions or insufficient segregation of duties between the Charter School and CMO. This request will be made by the Office of School Opportunities to the applicant after the applicant has received an approved completeness check. This answer will be reviewed by RIDE’s legal office before anything proceeds forward with the application". Under current practice, all application teams need to complete an RFP, with a full public comment period and public hearings and approval by the Council on Elementary and Special Education, in order to open a charter. RIDE has included a question in this year's annual subrecipient monitoring survey (which feeds into the annual risk assessment), asking Charters if they have a relationship with a Charter Management Organization (CMO). If they respond 'yes', we ask if they have written internal controls, policies and procedures specific to the CMO relationship and how the Charter School mitigates potential conflicts of interest, related party transactions and/or insufficient segregation of duties. We request that they upload a any written internal control, policies and procedures specific to the CMO relationship (if any). The survey with this revised language was sent out to subrecipients on April 19, 2024. Anticipated Completion Date: September 30, 2024 Contact Person: Mark Dunham, Chief Financial Officer, Department of Elementary & Secondary Education mark.dunham@ride.ri.gov

Finding 2023-040 – Corrective Action Plan There is no disagreement with the audit finding. The College has designated the Director of Information Security to oversee the information security function. The College has contracted with a firm to function as a virtual Certified Information Security Officer (vCISO) to support compliance as well as provide training and consulting services. The Assistance Vice President, Chief Information Officer is tasked with ensuring that the Written Information Security Program is updated annually and that compliance is maintained. Anticipated Completion Date: June 2024 Contact Person: Pamela Christman, Assistance Vice President, Chief Information Officer, Rhode Island College pchristman@ric.edu

Finding 2023-038 – Corrective Action Plan Auditee Views: SFRF reporting utilized physical posted date pulled from PowerBI environment. The issue with physical posted date is that the report can change based on when pulled. PRO project was not detailed in Annual Report. The blank sections of the downloaded reports are due to a US Treasury system issue that affects all States, not just Rhode Island. PRO began taking screenshots once it became aware of the problem and will continue to do so. There is a tedious review process that is completed for reporting on this data and information supplied to PRO by the entities. Corrective Actions: Modify the U.S. Treasury reporting process to utilize cash date to align with RIFANS federal transaction register both cumulatively and quarterly. Anticipated Completion Date: May 15, 2024 Add PRO project description to SFRF Annual report to U.S. Treasury. Anticipated Completion Date: July 31, 2024 Collect additional information from component unit agency to support provided reporting data. Anticipated Completion Date: June 30, 2024 Contact Person: Paul L. Dion, Ph.D., Director, Pandemic Recovery Office, Department of Administration paul.l.dion@doa.ri.gov

Finding 2023-037 – Corrective Action Plan Auditee Views: PRO met with the Department of Housing and the legal services vendors. The Department of Housing is collecting backup documentation for the vendors to support payment. This has been shared with PRO via SharePoint. The Department may also request additional backup documentation from the vendors to further support these costs. Corrective Action: Obtain additional documentation from the legal services vendors and maintain SharePoint to ensure PRO has access to supporting documentation. Anticipated Completion Date: Completed and Ongoing Contact Person: Tara Booker, Executive Director of Homelessness and Community Supports, Department of Housing tara.booker@housing.ri.gov

Finding 2023-030 – Corrective Action Plan We agree with the finding and are actively working to address the underlying issues impacting inconsistent subrecipient monitoring activities by state agencies acting as pass-through entities. The Grants Management Office developed and provided a 3-part in person (and recorded available on our website) training class on subrecipient monitoring in the fall of 2023. The training classes included monitoring best practice, in-person exercises and scenarios and an in-depth training and demonstration of the subrecipient monitoring module in the eCivis grant management system (GMS). As more subawards are issued through the GMS, we expect the monitoring module to be used to conduct subrecipient monitoring as required by federal rules/regulation. The training and new module in the GMS support the Grant-Making Regulation 220-RICR-20-00-2 which took full effect 7/1/23 and requires state agencies to issue subawards through the GMS. The regulation also specifically outlines the requirement of a risk assessment as part subaward issuance and informs agencies on the relationship between the risk assessment results and subrecipient monitoring. We believe these steps will significantly improve subrecipient monitoring activities conducted by state agencies and address this finding. Anticipated Completion Date: Completed. GMO continues to train and supporting/reinforcing control; expect to see improvements/results in the coming FY. Contact Person: Steve Thompson, Chief of Strategic Planning, Monitoring, and Evaluation, Grants Management Office, Office of Accounts and Control steve.thompson@doa.ri.gov

Finding 2023-032 – Corrective Action Plan RIDOH agrees with the finding and recommendation. This finding is centered around some local agency staff being inactive for longer periods of time (60+ days) and the security risk around them not being terminated or made inactive in our Crossroads system. While RI WIC is routinely notified of terminations and transfers of local agency staff, there are instances of people with varying degrees of access going over 60 days without accessing the system. It is sometimes due to a local agency staff person who is in more of an administrator role and not routinely working in the Crossroads system. RI WIC will review policies and procedures regarding user access to the Crossroads System and will work to strengthen and monitor controls for system access. Policies and procedures will be updated as needed, and internal controls will be implemented and documented. Anticipated Completion Date: December 31, 2024 Contact Persons: Ann Barone, Chief, Office of Women, Infants & Children, Rhode Island Department of Health ann.barone@health.ri.gov Anthony Manzi, WIC Fiscal Manager, Rhode Island Department of Health anthony.manzi@health.ri.gov

Re: Finding 2023-001 Significant Deficiency and Compliance with Special Tasks and Provisions Energy Northwest Management understands it is our responsibility to have adequate controls to ensure compliance with all provisions of a federal grant contract. To further enhance our internal controls, Energy Northwest will establish the following Corrective Action Plan: Corrective Action Plan to Be Taken – Management will develop a checklist process to be utilized for all federal grants that will outline the specific provisions of each contract, who is responsible for the provision and the due date of each provision. Prior to finalization of the checklist, a review of the checklist will be done to ensure it encompasses all the provisions of the contract. Energy Northwest’s procedures will be updated to include the checklist process. Responsible Parties to Ensure Corrective Action Is Taken – Accounting Manager and Accounting & Budgets Director. The Corrective Action Timeline –  Checklists for existing federal contracts completed – September 30, 2024  Procedure updated with checklist process – September 30, 2024

Name of Responsible Individual: Vice President of Finance and Administration (David Byrd) Corrective Action: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline. Anticipated Completion Date: June 30, 2024

Condition: Obligations were overstated by approximately $800,000 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: Will adjust on March 31, 2024 Project and Expenditure report. Anticipated Completion Date: April 30, 2024 Contact: Nicole Pearsall, Town Accountant

Since taking over the financial management of ELFHCC in December 2022 we have reorganized the financial reporting process and have been able to ensure meaningful analysis on a regular and continual basis. Policies and procedures have been created, changed, updated and Board approved. All financial reporting is prepared, analyzed and presented each month without delay.

FRLS shared that as part of the corrective action plan, improved PAI services by changing pro bono coordinators from paralegals to attorneys to better work with private attorneys and respective bar associations throughout our service areas. FRLS has also reestablished connections with our respective service partners throughout the pandemic, rebuilding and providing excellent services through our pro bono partners. PAI remains one of our top priorities in expanding our program services. Our program improvements, including pro bono assistance via virtual and courthouse clinics have resulted in more PAI services to our client communities. We have increased attendance at our annual bench and bar events to raise PAI awareness in our service communities. FRLS is in the process of creating a “low bono” program to expand our network of private attorneys and meet our required 12.5% spending requirement. FRLS will continue to evaluate its policies and procedures surrounding monitoring of PAI compliance to ensure that only allowable pro bono cases are accepted. This will be completed by December 31, 2024.

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Kaaterskill Commons, Inc. agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Bryan Mahoney, Chief Financial Officer, at (518) 828-8090.

2023-001-Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings noted on the FY 22/23 audit regarding expenditures and obligations were in direct correlation with the findings noted on the FY 21/22 audit. At the close of the FY 21/22 audit, quarter one and quarter two reports had been filed with Treasury. Leading into quarter three, corrections to reporting obligations were being addressed and corrected. As of the fourth quarter reporting cycle, all expenses and obligation issues were corrected. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson, Budget and Management Services Director Planned completion date for corrective action plan: As mentioned above, this has already been addressed as part of the FY 21/22 audit that was finalized in April 2023, 7 months into FY 2022/23. The Budget Office will continue to follow the procedures that were put into place more than halfway through FY 22/23.

Condition: As of the June 30, 2023 reporting date, the City’s Project and Expenditure Reports understated expenditures by $629,040. Also, obligations were overstated by approximately $15,000,000. Corrective Action Planned: The City has implemented reconciliation procedures with the City Auditor and the City ARPA Director to reconcile the general ledger with the US Treasury portal prior to submission on a quarterly basis. The ARPA Director reached out to the US Treasury and communicated concerns that obligations cannot be edited on the portal and received guidance on remedies to edit obligations. Anticipated Completion Date: April 30, 2024 Contact: Bridget Almon, Director of Financial Services Kara Humm, ARPA Director Sedryk Sousa, City Auditor

Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 – 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR §200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Passthrough entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters. (2) Performing on-site reviews of the subrecipient's program operations. (3) Arranging for agreed-upon-procedures engagements as described in § 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: 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 comply 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). Condition: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific programs and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Action taken in response to findings: OCR has submitted the subaward agreement to include all required information for review and approval in SPEED. The subaward agreement is awaiting approval and will be sent to the Office of Finance in April 2024. Name of the contact person responsible for corrective action: Ameria Williams, Budget and Human Resources Manager. Planned completion date for corrective action plan: April 30, 2024. Explanation of disagreement with audit findings: There is no disagreement with the audit findings. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient. Any questions concerning the findings or corrective action plan can be directed to Euniesha Davis, Director, OCR, at 301-952-4729.