Corrective Action Plans

Cluster Name: Elementary and Secondary School Emergency Relief Assistance listing numbers and program names 84.425U COVID-19 – Education Stabilization Fund – American Rescue Plan Elementary and Secondary School Emergency Relief (ARP-ESSER) Agency: Arizona Department of Education (ADE) Name of contact person and title: Braulio Garcia, Chief Procurement Officer Anticipated completion date: June 2026 Agency’s Response: Concur 1. Follow federal regulation, State law, and the Arizona Procurement Code for procurements related to federal grant awards. ADE will conduct all procurements related to federal grant awards in compliance with 2 CFR Part 200, State law, and the Arizona Procurement Code, using the same policies and procedures applied to non-federal funds, as required by federal regulations. ADE will ensure appropriate procurement methods are used and documentation is maintained. Competition Impracticable (CI) procurements will require prior review and approval by the State Procurement Office (SPO) before implementation, and ADE procurement staff will consult with the SPO as needed for technical assistance to ensure ongoing compliance. Implementation is ongoing and monitored through procurement file reviews and established internal controls. 2. Update and implement policies and procedures and responsible employees to use competitive procurement methods or otherwise obtain approval from the State Procurement Officer and to prepare written determinations for exceptions to using competitive procurement methods, such as noncompetitive waivers, when purchasing goods and services from third-party vendors. ADE Procurement is currently updating internal policies and procedures, which shall be implemented by June 30, 2026, to ensure appropriate procurement employees consistently use competitive procurement methods or obtain prior approval from the State Procurement Office (SPO) when exceptions apply. The updated procedures will require written determinations and justifications, such as a Competition Impracticable (CI), for all exceptions to competition and will clearly define responsibilities and approval requirements when purchasing goods and services from third-party vendors. Procurement staff will follow the revised procedures for all applicable procurements, and compliance will be monitored through procurement file reviews and established internal controls.

Assistance listing numbers and program names 84.010 Title I Grants to Local Education Agencies 84.367 Supporting Effective Instruction state Grants, Title II (formerly Improving Teacher Quality State Grants) 84.425D COVID-19 – Education Stabilization Fund –Elementary and Secondary School Emergency Relief (ESSER) 84.425U COVID-19 – Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP-ESSER) Agency: Arizona Department of Education (ADE) Name of contact person and title: Matthew McClary, Grants Management Compliance Officer Nicole von Prisk, Deputy Associate Superintendent Anticipated completion date: October 2027 Agency’s Response: Concur The Arizona Department of Education has worked in cooperation with our vendor to correct outdated SQL queries that were identified and return only approved grant award amounts rather than all awarded amounts, regardless of approval status. This issue was causing several subaward amounts to incorrectly update. Moving forward, we are ensuring that the original award amounts are being queried and, in return, reported within SAM.gov (System for Award Management). Additionally, through the reconciliation process each month, correct award amounts will align with the corresponding Federal Award Identification Number (FAIN). Reports being submitted late: We have implemented an automated monthly reporting workflow/schedule which will help ensure required FFATA reporting is submitted timely. This process automation helps prompt monthly FFATA reporting uploads by leveraging office tools that are readily available and ensures monthly upload deadlines are met by automatically scheduling the task and requiring follow-up by the assignee. In January of 2024, the staff assigned to FFATA uploads changed again (for the fourth time in a year) and at that point a new staff member assumed responsibility for FFATA uploads. As numerous corrections needed were discovered through the reconciliation process, new reports were uploaded. Some of these were original uploads for entities that were missing SAM.gov (formerly FSRS) information altogether, and some were corrections to previously uploaded yet incorrect information. With each monthly upload, a new date was being captured and while some of the information was new entity award information, not all the information being updated was untimely. This has been a long and arduous process, and we look forward to not having continued FFATA findings, as we are making progress to correct award information for all federal grants moving forward from this point. Inaccurate and/or Incomplete Data: Our Compliance Officer conducts a monthly reconciliation of current SAM.gov award information in coordination with either the Lead Grants Coordinator or the Deputy Associate Superintendent. During this review, any missing, inconsistent, or duplicate data is identified and corrected prior to the upload into SAM.gov. Once the subawards have been uploaded, the reconciliation process is repeated to verify the accuracy of the information recorded within SAM.gov. Note: On October 30, 2025, we became aware that USASpending.gov was no longer updating subawards to correspond with the data we have submitted in SAM.gov. We raised a service desk ticket to USA Spending (Case 00089604), but the issue is ongoing. USA Spending has stated that they “are aware of an issue with the outbound API in SAM to USA Spending, but due to the lapse in funding, the SAM team working on this specific issue has been furloughed until funding is restored.” The reconciliation process where subawards uploaded to SAM.gov are compared to the data in USASpending.gov continues to be heavily impacted until this service is restored. To ensure accurate documentation and timely resolution of system related challenges encountered when submitting subawards in SAM.gov, the Compliance Officer has implemented a formal Incident Tracking process. All technical issues are logged at the time they occur, and each incident is subsequently submitted to the Federal Service Desk (FSD.gov). Upon submission, the incident is assigned an official Incident Request ID along with a corresponding date and time stamp, enabling effective monitoring and follow‑up. Grants Management will establish, implement, and enforce internal and external controls to ensure that risk is minimized and can be appropriately evaluated during any monitoring conducted by the agency. The internal and external controls that will be implemented will establish guidelines addressing conflicts of interest, related-party transactions, and insufficient segregation of duties. Implementation will be based on reference materials provided by the U.S. Department of Education Office of Inspector General, as well as technical assistance from organizations with legal and governmental expertise. ADE’s software will be updated appropriately.

Assistance listing numbers and program names 84.010 Title I Grants to Local Education Agencies 84.367 Supporting Effective Instruction state Grants, Title II (formerly Improving Teacher Quality State Grants) Agency: Arizona Department of Education (ADE) Name of contact person and title: Sarka J. White, Deputy Associate Superintendent Anticipated completion date: December 2027 Agency’s Response: Concur Monitoring of CMO We will update protocols and implement an annual monitoring process specifically for charter schools with CMO relationships by integrating defined procedures to evaluate additional conflicts of interest, related party transactions, and segregation of duties concerns, while assigning a programmatic risk label in addition to the one assessed by Grants Management. To ensure accurate identification and appropriate separation of responsibilities, Title I and Title II will incorporate procedures for detecting CMO associations within both the grant review process and programmatic monitoring functions, supported by coordinated information sharing across relevant departments. Updated policies will also include requirements for disclosure of organizational associations and embed these indicators into the LEA level risk framework that determines monitoring frequency and representation based on assessed risk. Checks and balances will include programmatic follow-up on these disclosures prior to review of funding applications and or any assistance provided. Title I and Title II will revise monitoring tools to include CMO specific review steps, provide targeted staff training on identifying CMO relationships and apply enhanced oversight procedures, and carry out funding and program approval activities and monitoring activities. These can be in the form of financial and performance report reviews, Grant approvals, Data submissions, technical assistance, and onsite or virtual visits, in alignment with the strengthened risk-based model. Completion will be demonstrated through finalized procedures, documented staff training, and the application of revised monitoring methods during the next annual grant and monitoring cycle. Monitoring – Programmatic – Grant Monitoring We have revised LEA monitoring policies and procedures to incorporate coordinated processes between departments for clear identification of charter schools with CMO relationships, require now disclosure of organizational associations, and strengthen oversight of conflicts of interest, related party transactions, and segregation of duties risks. Updated procedures also define a structured, risk-based monitoring framework that assigns LEA monitoring levels, representation, and monitoring frequency based on assessed risk, independent of CMO affiliation, while integrating new indicators into monitoring tools to support consistency through equal representation and ensuring each LEA is treated as an individual LEA without respect to associations. Staff have and will continue to receive targeted training on the revised requirements, and completion will be demonstrated through the approval and publication of updated procedures, documented staff training, and application of the enhanced risk-based monitoring approach during the next LEA monitoring cycle.

Assistance listing number and program name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Agency: Governor’s Office of Strategic Planning and Budgeting (Office) Name of contact person and title: Ben Henderson, Director Governor’s Office of Strategic Planning & Budgeting Anticipated completion date: December 31, 2026 Agency’s Response: Concur The Office agrees with this finding and will continue to take corrective action to bring the program fully into compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Federal grant reporting requirements. The Office recognizes the importance of transparency in the use of Federal grants and has taken significant corrective action to resolve any inaccuracies in Federal grant reporting. The Office has implemented specific actions to ensure reporting inaccuracies and program expenditure understatements/overstatements do not occur. During fiscal year 2025 and 2026, the Office has taken corrective action to improve SLFRF reporting processes, including conducting weekly reviews and monthly reconciliations as outlined: ● Award Reconciliation — The Office has conducted a comprehensive review and extensive reconciliation of all awards to identify reporting inaccuracies. This reconciliation will continue as an ongoing process through the SLFRF closeout. ● Expenditure Reconciliation — The Office staff responsible for preparing the SLFRF quarterly reports is completing the reconciliation of all expenditures to the State’s accounting records, which are the official expenditures for the program. This will continue as an ongoing process through the SLFRF closeout. ● Enhanced Reporting Mechanisms—The Office will review, correct, and/or resubmit any inaccurately reported information. The staff responsible for preparing the SLFRF quarterly reports is no longer reconciling to the Office’s internal grants-management system. Reports will be compiled from the State’s accounting records, which are the official record of expenditures made for the program. The Office will investigate and resolve any differences prior to submitting the report to the federal agency. This will continue as an ongoing process through the SLFRF closeout. ● Update Procedures—Based on the comprehensive review noted in the response above, the Office is continuing to implement improved reporting procedures to ensure the accurate submission of grant expenditure data. This includes revised standardized templates, improved guidelines, and enhanced communication channels to improve reporting accuracy. ● Ongoing Training — Office staff now attend ongoing internal and external training to improve their understanding of compliance requirements, identify noncompliance, and actively reduce the risks of reporting errors. During fiscal years 2025 and 2026, staff engaged in 18 professional development opportunities, including monthly federal reporting calls, grants management webinars and trainings, internal training sessions, state accounting system training, and participation in a Microsoft data conference. These ongoing efforts reflect our commitment to staying current with compliance requirements and best practices. The Office will continue to strengthen internal controls to prevent similar issues in the future. This involves strengthening oversight, providing additional training to staff members in reporting processes, and implementing regular quality assurance checks. As of this date, the Office has allocated sufficient resources to comply with the award terms and program reporting requirements by establishing the Grants Technology and Data team dedicated to overseeing the necessary SLFRF program reporting procedures. The Office is committed to eliminating any risk through a full reconciliation of expenditures by the end of the program, which occurs during fiscal year 2027.

Assistance listing number and program name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Agency: Governor’s Office of Strategic Planning and Budgeting (OSPB) Arizona Department of Housing (ADOH) Arizona Department of Water Resources (ADWR) Arizona Office of Tourism (AOT) Industrial Commission of Arizona (ICA) Name of contact persons and titles: Ben Henderson, Director Governor’s Office of Strategic Planning & Budgeting Keon Montgomery, ADOH Assistant Deputy Director of Programs Will Palmisano, ADWR Finance and Administration Assistant Director Mary-Ellen Kane, AOT Assistant Deputy Director Sylvia Simpson, ICA Chief Financial Officer Anticipated completion date: See below Agency’s response: Concur OSPB anticipated completion date: April 2027 As indicated by the auditors, OSPB has demonstrated compliance with subrecipient monitoring requirements in FY24. The audit report limits OSBP’s inclusion in this finding to the questioned costs ($1,623,846) identified by OSPB through its subrecipient monitoring. However, the identification of questioned costs is not evidence of a deficiency in OSPB’s subrecipient monitoring; rather, the opposite, it demonstrates that OSPB has sound internal controls and an effective subrecipient monitoring system in place. Accordingly, OSPB will continue with the existing comprehensive subrecipient monitoring framework as outlined below: ● On-going Grantee Support - The Office provides a variety of subrecipient support including technical assistance, Communities of Practice(COP), and regular status check meetings. ● Training - Office staff facilitate ongoing training and provide resources and guides to improve understanding of compliance requirements and provide tools to support proper grants management. ● Financial Report-Reimbursement Requests—The Office reviews the grantee's financial reports to ensure costs align with the approved budget, program objectives, and federal cost principles. ● Performance Reports—The Office reviews the submission of programmatic reports to track progress on grant goals. ● Single Audit Reports—The Office confirms any required subrecipient Single Audits, reviews a copy of the most recent Single Audit Reporting Package (SARP), issues any necessary management decisions, and conducts follow-up monitoring of Corrective Action Plans. ● Risk Assessment (RA)—The Office conducts a Risk Assessment (RA) of grantees when applying for grants to inform the grant award decision and possible grantee oversight or restrictions. Additionally, the Office conducts an annual RA of any grantee currently awarded funding. ● Monitoring Reviews - The Office utilizes the RA results to prioritize high risk grantees to be reviewed through a desk or on-site monitoring. Medium risk grantees will receive additional support and will be referred to our Compliance and Reporting team for further review if additional concerns arise. The Office has implemented all past recommendations and OSPB is committed to continuing these ongoing efforts to actively reduce the risks of waste, fraud, and abuse of federal dollars through our subrecipient monitoring process. OSPB will continue Coronavirus State and Local Fiscal Recovery Funds subrecipient monitoring and follow-up through the grant closeout in April 2027. ADOH anticipated completion date: March 2026 The ADOH has begun to develop and implement formal, documented subrecipient risk assessment procedures to ensure monitoring activities are aligned with assessed levels of risk. This will include establishing standardized criteria to evaluate subrecipient risk and documenting risk determinations. These enhancements are also consistent with recommendations identified in the State’s most recent Sunset Audit, and the Agency has already begun implementation of these procedures. The ADOH will update policies and procedures accordingly and provide staff training to ensure consistent application. These actions will strengthen internal controls and ensure compliance with applicable subrecipient monitoring requirements. The ADOH will implement procedures to strengthen subrecipient monitoring related to Single Audit requirements. This will include verifying submission to the Federal Audit Clearinghouse, obtaining and retaining copies of all applicable Single Audit reports, and maintaining a tracking mechanism to document receipt and review. The ADOH will also establish procedures to review audit findings and ensure appropriate follow-up, including verification of subrecipient corrective actions, and will support consistent implementation. ADWR anticipated completion date: December 31, 2026 Before approving an application from an eligible subrecipient for federal grant monies, ADWR as a passthrough entity, will conduct a risk assessment of the subrecipient as part of the initial award approval. ADWR will create a standardized checklist that will enable ADWR to make an informed decision regarding what monitoring tasks will be necessary consistent with 2 CFR 200.332. Once an eligible subrecipient applies for federal grant monies, ADWR will require the applicant subrecipient to fill out the checklist and establish a monitoring program consistent with the results. ADWR will develop staff training and a standard work to implement this program. If the award spans more than one year, the results of any applicable single audits will inform ADWR if changes to the monitoring program for a particular subrecipient are required. As part of a program standard work, ADWR will send a questionnaire to subrecipients regarding federal award expenditures and remind them of any single audit requirements as well as expected completion date of any applicable audits. Failure of any prescribed monitoring items will trigger award review and possible reclassification of risk, additional monitoring, and/or withholding of pending reimbursements until the subrecipient remedies an issue. AOT anticipated completion date: March 20, 2026 AOT has established a process to verify that subrecipients who receive a grant award greater than $750,000.00 are able to provide a current single audit. AOT will provide sub recipients additional written documentation identifying required completion dates and any additional instructions required. Processes and procedures have been developed and implemented. The program has concluded and no further action will be taken. AOT has established a process to ensure the required backup documentation provided by the subrecipient is acceptable for reimbursement. AOT will continue to communicate with OSPB on updates to policy to ensure the processes and procedures are being implemented within federal and state funding guidelines. The program has concluded and no further action will be taken. ICA anticipated completion date: December 31, 2025 The ICA concurs with the finding regarding subrecipient monitoring. The ICA’s involvement as a pass-through entity for the SLFRF program was a unique, one-time occurrence designed to facilitate the equitable distribution of funds to Arizona fire districts based on a methodology approved by the Office of Strategic Planning and Budgeting (OSPB). The ICA does not expect to serve as a pass-through entity for federal funds in the future. While the ICA implemented rigorous validation steps, including the thorough review of payroll records, receipts, and attestations prior to any reimbursement, the agency recognizes that formal risk assessments and subaward agreements were not executed at the onset of the program. The ICA became aware of these specific documentation deficiencies through the audit process after the program had already ended on December 31, 2025. The ICA will address the underlying control deficiency by updating its internal grant management procedures to ensure in the event the agency was to act as a pass-through entity again, formal risk assessments and standardized subaward agreements would be completed by the subrecipient as part of the requirements to receive federal monies. Additionally, the ICA has since obtained 100% of the required single audit reports from the applicable subrecipients and has verified that all necessary corrective actions for unrelated findings have been addressed.

Assistance listing numbers and program names: 21.023 COVID-19 Emergency Rental Assistance Program 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Agency: Department of Economic Security (DES) Name of contact person and title: Molly Bright, Community Services Division Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Division will review and confirm that benefits payments paid to or on behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Update existing policies and procedures to include a post-review of the benefits subsystem’s automated review of eligibility requirements, such as verifying the income thresholds and geographic location aligned with the Division’s written policies and procedures, and supported by required documentation. The Division should correct any inaccurate eligibility determinations identified during the post-review. Emergency Rental Assistance Program policies and procedures require validation of eligibility based upon substantiating applicant documentation, including household income and geographic location. The Division will update Division policy to include a post-review process to identify and correct any errors or discrepancies. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Division will allocate sufficient staffing resources to evaluate program benefits applications and provide training on eligibility requirements and allowable benefit payments. 4. Work with the federal agencies to resolve the $64,131 in program funds that were spent in violation of federal regulations, policies and procedures, and may need to be returned to the federal agencies. The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Division will review and confirm that benefits payments paid to or on behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Update existing policies and procedures to include a post-review of the benefits subsystem’s automated review of eligibility requirements, such as verifying the income thresholds and geographic location aligned with the Division’s written policies and procedures, and supported by required documentation. The Division should correct any inaccurate eligibility determinations identified during the post-review. Emergency Rental Assistance Program policies and procedures require validation of eligibility based upon substantiating applicant documentation, including household income and geographic location. The Division will update Division policy to include a post-review process to identify and correct any errors or discrepancies. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Division will allocate sufficient staffing resources to evaluate program benefits applications and provide training on eligibility requirements and allowable benefit payments. 4. Work with the federal agencies to resolve the $64,131 in program funds that were spent in violation of federal regulations, policies and procedures, and may need to be returned to the federal agencies. The Division will coordinate with applicable federal agencies to resolve these unallowable costs.

Assistance listing number and program name: 21.027 Coronavirus State and Local Fiscal Recovery Funds Agency: Department of Economic Security (DES) Name of contact person and title: Molly Bright, Community Services Division Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: 1. Include information required by federal regulations in its subawards to subrecipients, including federal award identification information and any additional requirements the Department imposed on the subrecipients to meet its responsibilities under the federal award. The Department will analyze and improve its information dissemination practices to ensure that all information required by federal regulations is included in the subawards to subrecipients. This will include the federal award identification information and any further requirements the Department imposes on the subrecipients to meet the responsibilities under the federal award and applicable state laws. 2. Perform required monitoring of its subrecipients and their compliance with the award terms and program requirements. The Department will revise its agency-wide policies and procedures related to single audit requirements for pass-through entities to include guidance regarding how to establish effective subrecipient monitoring procedures. The Department will also offer additional subrecipient monitoring guidance for programs administered by divisions with existing subrecipient monitoring findings. A divisional Monitoring and Compliance Policy and Procedure Manual is currently being developed to ensure compliance with these regulations across all program areas, including those subject to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Grant. 3. Develop, implement, and train all divisions on entity-wide written subrecipient-monitoring policies and procedures requiring all divisions to: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward by including in its award terms with subrecipients information necessary for the subrecipient to administer the program in accordance with federal requirements. Required information includes federal award identification, all requirements of the subaward, any additional requirements the Department imposes on the subrecipient for the Department to meet its responsibilities under the federal award, indirect cost rate, and audit and closeout requirements. b. Assess the risk of each subrecipient’s noncompliance and carry out monitoring activities based on those risk assessments such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. c. Review financial and performance reports. d. Verify subrecipients receive timely single audits, if required; follow up on and ensure that corrective action is taken on any audit findings that could potentially affect the program; and issue management decisions for any audit findings pertaining to the federal award. e. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. In addition to the revisions in policy and procedures outlined in Recommendation #2 above, the Department will train staff responsible for administering compliance requirements for pass-through entities. This training will include instructions to formulate a risk assessment, review controls related to compliance requirements, review timely single audit submittal, follow up on audit findings, issue management decisions for findings, and maintain adequate documentation of monitoring procedures. Furthermore, the training will be inclusive of proper information dissemination practices aimed at ensuring every subaward is clearly identified to the subrecipient as a subaward by including in its award terms with subrecipients information necessary for the subrecipient to administer the program in accordance with federal requirements. The training and revised procedures will be provided to all staff responsible for administering programs with pass-through entities. 4. Allocate sufficient resources, such as staffing, to comply with the award terms and program requirements, and designate individuals within each division to perform necessary subrecipient-monitoring procedures. The Department will conduct analyses to determine resources needed, including staffing, to ensure compliance with applicable requirements. For example, the Department will assess the efficiency of its subrecipient-monitoring procedures, estimate future workloads, determine staffing needed to meet those workloads, and assign sufficient staff the responsibility for ensuring compliance with each requirement outlined in the federal award. The Department will also ensure the staff responsible for administering the compliance requirements prioritize this responsibility and communicate anticipated compliance deficiencies to management.

Assistance listing number and program name: 21.023 COVID-19 Emergency Rental Assistance Program Agency: Department of Economic Security (DES) Name of contact person and title: Molly Bright, Community Services Division Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department will prepare and retain detailed documentation, including system reports, queries, screenshots, and other evidence, to support the program information reported to the federal agency for each Emergency Rental Assistance Program (ERAP) award. DES will also abide by its ERAP policies and procedures to retain all records related to the award for a period of 5 years after all federal funds are expended. The Department sunset the ERAP program on October 13th, 2023, due to an exhaustion of ERA 1 and ERA 2 funding.

Assistance listing number and program name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Agency: Department of Economic Security (DES) Office of Economic Opportunity (OEO) Name of contact persons and titles: David Almaraz, DES DERS Business Administrator Stephen Sifuentes, OEO Finance Administrator Senior Anticipated completion date: See below Agency’s Response: Concur DES Anticipated completion date: December 31, 2026 The Department will address the audit recommendations by amending its ISA subaward with the Arizona Office of Economic Opportunity. The Department will also adjust its subrecipient monitoring schedule, procedures and offer training and assistance on conference-related requirements to the Arizona Office of Economic Opportunity. OEO Anticipated completion date: June 30, 2027 The Office of Economic Opportunity (OEO) acknowledges the finding regarding the use of WIOA Dislocated Worker Formula Grant funds for conference meals and promotional items. To address these concerns, OEO has undertaken proactive measures to strengthen internal controls, enhance oversight, and improve compliance with federal cost principles. As such, OEO will utilize these findings to strengthen its existing system, address any identified deficiencies, and continue to enhance fiscal management. Through these corrective actions, the OEO is committed to full compliance and the effective stewardship of federal funds. 1. Ensure Summit costs charged to the WIOA federal program are appropriate, necessary, and managed to minimize charges to the federal award. The OEO acknowledges the auditors’ findings regarding the management of Summit costs charged to the Workforce Innovation and Opportunity Act (WIOA) federal program. OEO is committed to ensuring that all expenditures are appropriate, necessary, and managed with the highest level of fiscal responsibility to ensure charges are necessary and allowable to the federal award. To address this finding, OEO will collaborate closely with the Arizona Department of Economic Security (ADES) to develop and implement comprehensive formal policies and procedures governing the State Workforce Development Board and WIOA funded events including Summit expenditures. Our joint efforts will focus on implementing a documented review and approval process to ensure costs charged to the federal award are supported by documentation and evaluated in accordance with 2 CFR §§ 200.403. As part of this corrective action, the process will integrate cost-containment measures into the planning and approval of the events budget planning phase. This will include requiring staff to assess whether proposed costs are necessary, reasonable, allocable and limited to helping the workforce development system achieve the purpose of the Workforce Innovation and Opportunity Act (WIOA). OEO and ADES will conduct working sessions to develop, implement, and monitor these protocols, with the goal of finalizing a standardized procedure for all WIOA-funded event expenditures. This approach ensures consistency across agencies and establishes clear oversight to prevent recurrence. 2. Develop and implement written procedures, including a standardized review process, to ensure that costs charged to the WIOA federal program are allowable prior to requesting reimbursement from DES. The OEO recognizes the importance of verifying the allowability of expenditures prior to the reimbursement phase. We concur that a standardized documented review process is necessary to maintain fiscal integrity and compliance of WIOA federal program funding and federal regulations. OEO, in partnership with the ADES, will develop and formalize written internal control procedures designed to vet all costs before they are submitted to ADES for reimbursement. The proposed standardized review process will align with existing practices for monitoring and expending federal funds as described under WIOA for the State Workforce Development Board and will include: ● Pre-submission verification: Implementation of an internal review checklist based on 2 CFR 200 Subpart E Cost Principles and applicable State policy. This will ensure that every line item is: ○ Allowable under both WIOA statutory requirements and federal cost principles. ○ Allocable to the specific federal award in proportion to the benefits received. ○ Compliant with the State of Arizona Accounting Manual ○ Documented with sufficient supporting evidence (pictures, invoices, receipts, and justifications) to withstand audit scrutiny. ● Standardized approval workflow: Establishment of a clear designated approval framework. ● Policy Integration: These procedures will be codified into an OEO Fiscal Manual, providing staff with a clear roadmap for processing WIOA-related expenditures. OEO will coordinate with ADES technical assistance teams to ensure our internal review templates align with ADES’s appropriate reimbursement systems. This collaborative design phase will ensure that once a request reaches ADES, it has already undergone a vetting process, thereby reducing errors. 3. Work with federal grantor and/or DES to resolve the $90,015 of questioned costs associated with the 2024 Summit and any subsequently held Summits. OEO will collaborate with the ADES, the primary grant recipient, to establish the most appropriate course of action for resolving any unallowable expenditures. Initially, OEO will work with ADES to precisely define the actual allowable amount based on programmatic cost allowability, which may require consultation with the original federal grantor, for final clarification on disputed cost. Subsequent steps for resolution will be guided by ADES’s direction and the requirements of the federal grantor.

Assistance listing numbers and program names 10.558 Child and Adult Care Food Program Agency: Arizona Department of Education (ADE) Name of contact person and title: Cara Alexander, Deputy Associate Superintendent Anticipated completion date: December 2026 Agency’s Response: Concur We have an established process in place for collecting the information necessary to determine total fiscal year expenditures for federal awards (the questionnaire) for entities that do not participate in any federal programs housed within the ADE's Grants Management Enterprise. The policy and procedures will be updated by April 1, 2026, to the following: (1) include additional internal controls such as the annual Child and Adult Care Food Program renewal process and serious deficiency process; and (2) detail the procedures to review single audit reports for findings related to the program and issue management decision letters when applicable. Finally, training will be provided to personnel responsible for collecting and reviewing the questionnaires and single audit reports when submitted.

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

Finding Reference: 2024-007 Finding Title: Timecard Approval Controls – Payroll Charge to Federal Grant, Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Scott Dolude, Director of Payroll, Financial Affairs, (312) 322-6526 Planned Corrective Actions: 1. Timecard Approval Requirements for Federal Grants: Management will reinforce payroll control procedures to require that all employee timecards charged to Federal grants are reviewed and approved by designated supervisors in a timely manner and in accordance with established payroll deadlines. Specifically, that all required approvals must be completed prior to payroll processing and fiscal period close to ensure the allowability, accuracy, and proper allocation of costs charged to Federal awards. By June 30, 2026, management will send an email to all impact supervisory and management personnel responsible for time review and approval processes. 2. Documentation Standards and Audit Trail: Management will establish formal documentation standards to ensure that evidence of supervisory review and approval, including approval dates, is consistently retained in a secure, centralized system. These standards will support a clear and retrievable audit trail demonstrating compliance with the payroll documentation and allowability requirements of 2 CFR §200.430(i). 3. Monitoring and Compliance Oversight: Management will implement periodic monitoring procedures to assess compliance with timecard review and approval requirements. These procedures will include exception reporting, timely follow-up on identified deficiencies, and management review of monitoring results. Corrective actions will be implemented, as necessary, to address recurring or systemic issues related to untimely, incomplete, or undocumented approvals. Based on the results of monitoring processes, Director of Payroll and Timekeeping will conduct organizational, departmental, or team-based follow-up to address non-compliance or other issues. Anticipated Completion Date: 06/30/2026

Name of Contact Person: Willie Mack Carawan, Jr., Finance Director Corrective Action/Management's Response: This finding is primarily the result of turnover/ transition/ reporting access of key personnel. Management is working with staff member to establish contact with reporting agencies and to gain the necessary access for reporting purposes, as well as reporting requirements. Proposed Completion Date: As soon as the discrepancy was identified by the auditor, management began working with staff to list their points of contact in the likelihood they are not available to meet reporting requirements for the year ending June 30, 2024.

CORRECTIVE ACTION PLAN The Town of Billerica, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17th Floor Boston, MA 02109 Audit Period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding 2024-002: Lack of Segregation of Duties – Grant Reporting Approval and Submission Views of Responsible Officials: The Town acknowledges the finding and recognizes the importance of maintaining adequate internal controls over federal grant reporting, including appropriate segregation of duties. We will be implementing additional procedures to ensure adequate preparation and review procedures to ensure accurate reporting to oversight agencies. Official Responsible for Implementing Corrective Action: Amit Chhayani Town Accountant

Finding Number: 2024-051 Finding Name: Failure to Report Subaward Information Required by FFATA Finding Condition(s): The Illinois Department on Aging (IDOA) failed to report information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrecipients of the Aging Cluster program. Additionally, we noted IDOA did not establish adequate internal controls over FFATA reporting to ensure all subawards were reported as required. Name of Contact Person(s): • Teri McKeon, Deputy Chief Financial Officer / Bureau Chief Business Services - Illinois Department on Aging, Division of Financial Administration • Sarah Harris, Chief Financial Officer - Illinois Department on Aging, Division of Financial Administration Corrective Action(s): The IDOA is revising procedures to account for the new system FFATA information is entered into, updating the tool used to gather the information, and training of new staff to perform this duty. Proposed Completion Date: September 1, 2026

Finding Number: 2024-050 Finding Name: Failure to Accurately Prepare Financial Reports for the Aging Cluster Finding Condition(s): The Illinois Department on Aging (IDOA) did not prepare accurate federal financial status reports for the Aging Cluster (Aging) program. We further noted the supervisory review procedures performed for this report were not designed to operate at an appropriate level of precision to ensure financial reports are accurately prepared. Additionally, IDOA does not perform analytical procedures to identify potential errors or unusual fluctuations in reported amounts. Name of Contact Person(s): • Teri McKeon, Deputy Chief Financial Officer / Bureau Chief Business Services - Illinois Department on Aging, Division of Financial Administration • Sarah Harris, Chief Financial Officer - Illinois Department on Aging, Division of Financial Administration Corrective Action(s): The IDOA will tighten up the internal controls over its internal spreadsheet that is used to prepare the federal reports, as well as any corrections needed upon review, prior to entering the report into the payment management system. Proposed Completion Date: October 31, 2026

Finding Number: 2024-049 Finding Name: Inadequate Review of Subrecipient Single Audit Reports Finding Condition(s): The Illinois Department on Aging (IDOA) did not adequately document review of single audit reports received from its subrecipients for the Aging Cluster program on a timely basis. Name of Contact Person(s): • Teri McKeon, Deputy Chief Financial Officer / Bureau Chief Business Services - Illinois Department on Aging, Division of Financial Administration • Sarah Harris, Chief Financial Officer - Illinois Department on Aging, Division of Financial Administration Corrective Action(s): The IDOA does not currently issue management decision letters but is working with the Grants Accountability & Transparency Unit to retroactively complete management decision letters once staff is fully hired and trained. As the IDOA brings the management decision letters and reconciliations up to date, it will allow for a determination of whether additional staff for these functions is necessary to maintain compliance. Proposed Completion Date: October 31, 2026

Finding Number: 2024-048 Finding Name: Inadequate Review of Cash Draw Calculations Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not adequately document its review of cash draw calculations for the Crime Victim Assistance (CVA) program. Name of Contact Person(s): • Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management • Precious Taylor, Accounting Supervisor – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): ICJIA re-implemented reviews and approvals of its cash draw calculations in fiscal year 2025. Proposed Completion Date: October 22, 2024 – Completed

Finding Number: 2024-047 Finding Name: Failure to Accurately Prepare Financial Reports for the Crime Victim Assistance Program Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not prepare accurate federal financial status reports for the Crime Victim Assistance (CVA) program. Additionally, the auditors noted the supervisory review procedures performed for this report were not designed to operate at an appropriate level of precision to ensure financial reports are accurately prepared. Finally, the auditors determined that ICJIA does not perform analytical procedures to identify potential errors or unusual fluctuations in reported amounts. Name of Contact Person(s): • Rise Maye, Director – Illinois Criminal Justice Information Authority, Federal and State Grants Unit • Shataun Hailey, Program Manager – Illinois Criminal Justice Information Authority, Federal and State Grants Unit Corrective Action(s): The Enterprise Grants Management Information System (EGMIS) is ICJIA’s internal grants management system used to track subrecipient financial data, including recipients’ share match amounts. Currently, the EGMIS’ match report is the only source for the SF-425 reporting of recipients’ share match amounts. ICJIA will implement a standardized review process to ensure match data entered in the EGMIS is accurate and aligns with subrecipient periodic financial reports (PFRs) prior to SF-425 submissions. Proposed Completion Date: March 31, 2026

Finding Number: 2024-046 Finding Name: Inadequate Controls over the Review of Subaward Information Required to be Reported for FFATA Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) failed to report subaward information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrecipients of the Crime Victim Assistance (CVA) program. Name of Contact Person(s): • Rise Maye, Director – Illinois Criminal Justice Information Authority, Federal and State Grants Unit • Shataun Hailey, Program Manager – Illinois Criminal Justice Information Authority, Federal and State Grants Unit • Jude Lemrow, Administrative Assistant I - Illinois Criminal Justice Information Authority, Federal and State Grants Unit Corrective Action(s): ICJIA developed a new internal procedure that assisted agency personnel in identifying awards and amendments subject to FFATA reporting requirements and how to report required subaward information in accordance with FFATA. That procedure has since been updated to reflect current reporting and quality control practices and to include a supervisory review process prior to submission. The procedure was provided to all staff responsible for managing federal award funds and training was conducted. Proposed Completion Date: January 16, 2025 – Completed

Finding Number: 2024-045 Finding Name: Inadequate Controls over the Communication of Subrecipient Monitoring Results Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not consistently document supervisory reviews of the communication of on-site monitoring review results in accordance with ICJIA’s control procedures. Name of Contact Person(s): • Rise Maye, Director – Illinois Criminal Justice Information Authority, Federal and State Grants Unit • Shataun Hailey, Program Manager – Illinois Criminal Justice Information Authority, Federal and State Grants Unit Corrective Action(s): ICJIA revised its policies and procedures to incorporate expanded controls over the review of site visit reporting and grantee communications. Additionally, ICJIA developed and provided training to staff on the updated processes. ICJIA has updated and formalized procedures related to the communication of subrecipient monitoring results, and these procedures are currently in effect. Proposed Completion Date: October 31, 2024 – Completed

Finding Number: 2024-044 Finding Name: Inadequate Fiscal Monitoring of Subrecipients Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not follow its established policies and procedures for monitoring subrecipients of the Crime Victim Assistance (CVA) program. Name of Contact Person(s): • Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management • Karen Crawford, Chief Grantee Auditor - Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): ICJIA will include the additional factors outside the formal policy that may also need to be considered to ensure the process is comprehensive, practical, and fully aligned with program requirements. These considerations will be incorporated into the annual risk assessment documentation to strengthen consistency and oversight going forward. Proposed Completion Date: December 31, 2026

Finding Number: 2024-043 Finding Name: Inadequate Review of Subrecipient Single Audit Reports Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not adequately review single audit reports received from its subrecipients for the Crime Victim Assistance Program (CVA) program on a timely basis. Name of Contact Person(s): • Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management • Karen Crawford, Chief Grantee Auditor – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): ICJIA is in the process of hiring a full-time staff person to focus on the State’s Grant Accountability and Transparency Act (GATA) requirements over ICJIA’s reviews of its subrecipients’ single audit reports. Proposed Completion Date: July 1, 2026

Finding Number: 2024-042 Finding Name: Failure to Adequately Monitor Subrecipients Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not follow its established program monitoring policies and procedures for subrecipients of the Crime Victim Assistance (CVA) program for fiscal year 2024. Name of Contact Person(s): • Aaron O’Brien, Director – Illinois Criminal Justice Information Authority, Federal and State Grants Unit • Shataun Hailey, Program Manager – Illinois Criminal Justice Information Authority, Federal and State Grants Unit Corrective Action(s): In fiscal year 2025, ICJIA implemented updated subrecipient monitoring procedures and documentation requirements, which are currently in effect. Within the updated procedures, ICJIA enhanced internal tracking mechanisms and established clear timelines for the completion of monitoring reports and follow up to support timely and consistent subrecipient oversight. Additionally, ICJIA provided site visit training to grant staff to strengthen understanding and consistent application of the updated policies and procedures. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2024-041 Finding Name: Failure to Communicate Award Information to Subrecipients Finding Condition(s): The Illinois Department of Transportation (IDOT) did not follow its established policies and procedures for monitoring subrecipients of the Highway Planning and Construction program. Specifically, the auditors noted several subrecipient agreements that had missing required information. Name of Contact Person(s): • Teresa Cline, Agreement Analyst - Illinois Department of Transportation, Bureau of Local Roads and Streets (BLRS) • Melanie Turner, Grants Administration Section Manager - Illinois Department of Transportation, Bureau of Business Services (BoBS) • Aubrey Schuckman, Grants Unit Chief (Unit B) - Illinois Department of Transportation, Bureau of Business Services (BoBS) • Carissa Calloway, Grants Unit Chief (Unit A) - Illinois Department of Transportation, Bureau of Business Services (BoBS) Corrective Action(s): The required award information was incorporated into our standard agreement forms several years ago, and therefore, should be included in all agreements moving forward. The Office of Planning & Programming (OPP) agreement template has been in existence with the required fields since 2017 and the BLRS agreement template was updated in July 2021. Both agreement templates include all the required fields. To address the finding, IDOT has a process in place where a supervisor will review all draft agreements before they are finalized or sent to Office of Chief Counsel (OCC) for review. This should ensure that any missing or incorrect information is caught during the supervisor review process. Proposed Completion Date: March 31, 2026